Privacy Policy

Compound Real Estate Holdings, Inc. (“Compound,” “we,” or “us”) owns and operates the website www.compoundrealestatebonds.com (the “Site”) and mobile application, Compound Real Estate Bonds (the “App”). Compound is a financial services company that offers financial products and services to consumers(the “Services”). In providing our Services, we call information about you. We value the privacy of our Site visitors, App users, investors, registrants, and all others seeking to or using our Services (“you,” “your,” or “user”). OurPrivacy Notice discloses the type and nature of information we collect when you visit our Site, App, when you email or otherwise communicate with us and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any requests for personal or personally identifiable information will be used. Please note that this Privacy Notice applies to the data collection and practices of us, but also our subsidiary companies, Compound Real Estate Bonds, Inc., and affiliated entities.

Please read this PrivacyNotice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices set forth in this Privacy Notice, you may not use our Site, App or Services. However, by doing so, you agree to the terms set forth in this Privacy Notice, including as to the collection, use, and disclosure of your personal information.

Information We Collect About You and How We Collect It

‍The types of personal information we collect and share depends on how you interact with us and theService you seek to or utilize with us. Depending on how you interact with us and our Services, the information we may collect about you may include information that may personally identify you, such as your contact information including your name, address, email address, and telephone number(collectively, “contact information”).There may be instances, however, when we also collect categories of personal information that are more sensitive including you date of birth, bank account information, social security number, transaction history, account transactions, survey responses, and chat submissions (collectively “sensitive information”).We also gather automatic information such as your IP address, IMEI/UDID, MAC address, IDFA, AAID, location information, statistics on page views and traffic, and other information collected through cookies and other tracking technologies (collectively “device information”).Contact information, sensitive information, and device information are collectively referred to as “personal information”.We may also use third party analytics tools to help optimize our service, but no personally identifiable information is collected about you unless you explicitly submit that information via our fill in forms. We may keep records and copies of all correspondence if you contact us. We may keep details of transactions you carry out through the Site and App.

Use of Cookies, Web Beacons and Other Technologies
We use cookies to personalize our Services for you and to collect aggregate information about usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your devices to enable our systems to recognize your devices and to allow us to see how you use our Services. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

The cookies we use in connection with our Services include: Session cookies:

a. Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and to enable actions they must be logged into their Harvest account to perform.

b. Persistent cookies: Persistent  cookies usually have an expiration date in the distant future and remain     in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your Harvest account or to remember your choices for our Services.

c. Third-party cookies: We permit     certain third parties to place cookies through our Services to provide us     with better insights into the use of our Services and user demographics  and to advertise our Services to you. These third parties may collect     information about your online activities over time and across different     websites when you access or use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google     Analytics generates a cookie to capture information about your use of our     Services, which Google uses to compile reports on website activity for us     and to provide other related services. Google may use a portion of your IP     address to identify its cookie, but this will not be associated with any     other data held by Google. We may also permit third-party service     providers to place cookies for our Services, as indicated above, to     perform analytic or marketing functions where you are notified of them and     you have consented to the usage. We do not control the use of such     third-party cookies or the resulting information, and we are not responsible     for any actions or policies of such third parties.

Web beacons may be used to improve your experience on our Site,including helping provide you with content customized to your interests on bothour Site or in emails we send you. They also help us to understand whetherusers read email messages and click on the links contained within thosemessages so that we can deliver relevant content and offers. Our web beaconsmay collect some contact information (e.g., the email address associated withan email message that contains a web beacon). Compound and our partners usecookies, pixels, tags, or similar technologies on our digital properties. Wemay permit third-party service providers to collect and process someinformation from our digital properties through these or other automated means.We may also share personal information with those providers and may havesimilar arrangements with interest-based advertisers.

By accessing or using our Services, you consent to the placement of cookies onyour devices as described in this Privacy Notice. If you prefer not to receivecookies through our Services, you may control how your browser responds tocookies by adjusting the privacy and security settings of your web browser.Unless you set your browser settings to refuse all cookies, our system mayissue cookies when you access or use our Services. If you set your browsersettings to refuse all cookies, the performance of certain features of ourServices may be limited or not work at all.

‍Uses of Information We Collect from You
We use the personal information that we collect about you for the followingpurposes: Verify your identity Complete transactions and     transaction documents Enable automatic payments and     fund transfers For research and commercials     purposes, such as to improve our Services and our product offerings Contact you regarding a     transaction you requested or to discuss a problem with your account Maintain regular communications     with you as may be necessary to fulfill our obligations to you or to     execute requested transactions To provide you with information     about products or services you request from us or that may be of interest     to you To better understand the     behavior of our users and improve the Site, App, Services, and our product     offerings In any other way we may     describe when you provide the information; and for any other purpose with     your express consent To comply with regulators’     requests for information and meet other legal requirements To provide the functionality of     the Site and App To comply with applicable laws     and regulations related to the Site’s product offeringsWe may use personal informationfor the purposes described elsewhere in this Privacy Notice and internally forour general commercial purposes, including, among other things, to offer ourproducts and Services and products and services of third parties that we thinkyou might find of interest, but only we and our third-party service providersinvolved in distributing the offers or providing the products or services willhave access to your personal information. Our third-party service providerswill only be permitted to use personal information for that intended purpose.


We may use your email address to respond to yourinquiries and to provide you information about our Services. You may elect notto receive promotional emails from us either by “unsubscribing” to an email youreceive from us or by contacting us as indicated below. If you unsubscribe fromreceiving emails from us, we may still send you non-promotional emails, such asemails about your Harvest account or our ongoing business relations, unless youwithdraw your consent to receive electronic communications as provided in ourTerms of Use.

How We Share Your Personal Information
Like all companies similar to ours, we share customer personal information torun our business, including with our many trusted partners that perform vitalfunctions as part of our operations. Below sets forth the reasons we may shareyour personal information and to whom.

We work with (among others) providers of hosting services for the Site and App,electronic signature providers, and electronic payment service providers. Wemay engage third parties to help us carry out certain other internal functionssuch as account processing, funds transfer, client services, or other datacollection relevant to our business. Examples of third parties might includethose that perform data processing, reporting, tax documentation, custody orescrow services. Information is shared with these third parties only to theextent necessary for us to process the transactions you initiate or performother specific services, which may include your personal information. Ourpartners are legally required to keep your information confidential and secure.

We may share your personal information with unaffiliated third parties: (1) ifyou request or authorize it; (2) if the information is provided to helpcomplete a transaction for you; (3) if the information is provided to: (a)comply with applicable laws, rules, regulations, governmental andquasi-governmental requests, court orders, or subpoenas; (b) enforce our Termsof Use or other agreements; or (c) protect our rights, property, or safety orthe rights, property, or safety of our users or others (e.g., to a consumerreporting agency for fraud protection, etc.); (4) if the disclosure is done aspart of a purchase, transfer, or sale of services or assets (e.g., in the eventthat substantially all of our assets are acquired by another party, yourpersonal information may be one of the transferred assets); (5) if theinformation is provided to our third-party service providers to performfunctions on our behalf (e.g., analyzing data, providing marketing assistance,providing customer service, processing orders, etc.); (6) for our everydaybusiness purposes; or (7) as permitted by applicable law or otherwise describedin this Privacy Notice. When you are no longer our customer or investor, wecontinue to share your information as described in this Privacy Notice.

We may share your information with third parties to perform services on ourbehalf such as: Providing customer care and     technical support Sending marketing     communications and providing advertising services Measurement and reporting of     advertising frequency, attribution, and performance Personalizing customer     experience on our digital properties Conducting research and     analysis Linking your bank account for     purchases Processing ACH payments Detecting fraud and other     illegal activityWe may combine or share information among current or future CompoundReal Estate Holdings, Inc. companies, including affiliates and subsidiaries. Wemay also sell or share your identifiers to third parties for the purpose ofsending you marketing communications regarding their products and services inwhich you might be interested.

Sometimes we may be required to share personal information for legal reasons,for example, if we are required to do so by a regulation, court order, subpoenaor other legal process. We may also share information when we believe it isnecessary to comply with the law or to respond to a government request, or whenwe believe disclosure is necessary or appropriate to protect Compound, ourcustomers, or others.

We also may share personal information in connection with product or serviceofferings (including sharing with business partners or interest-basedadvertising). As a general rule, when we share personal information thecontract between us and the receiving party places specific limits on how theyuse the information, including that they must keep your informationconfidential and secure.Additionally, we may share personal information in the event of acorporate sale, merger, acquisition, joint venture, reorganization, divestiture,dissolution, liquidation, or similar event.

We may share your personal information with law enforcement or other governmentagencies as required by law or for the purposes of limiting fraud. We reservethe right to disclose your personally identifiable information when we believethat disclosure is necessary to protect our rights or to comply with a judicialproceeding, court order or legal process. We further reserve the right todisclose any of your personal information that we believe, in good faith, appropriateor necessary to take precautions against liability, to investigate and defendagainst any third-party claims or allegations, to assist government enforcementagencies, to protect the security or integrity of the Site or our services, orto protect the rights, property or personal safety of Compound, its users,issuers, or others.

We may also share your information with a buyer or other successor in the eventof a merger, divestiture, restructuring, reorganization, dissolution or othersale or transfer of some or all of our assets, whether as a going concern or aspart of bankruptcy, liquidation, or similar proceeding, in which personalinformation held by us about our Site users is among the assets transferred.

We may disclose analytics information, which is information that does notidentify you personally, with third parties as described in this Privacy Noticeand for our commercial purposes. 

We will share with our Service Providers only that information necessary forthem to perform their functions according to their respective privacy policies,and we require them to commit to use your personal information in accordancewith their respective privacy policies. Specifically, we partner with PlaidTechnologies, Inc. (“Plaid”) to gather user’s data from financial institutions.By using our service, you grant Plaid the right, power, and authority to act onyour behalf to access and transmit your personal and financial information fromthe relevant financial institution. You agree to your personal and financialinformation being transferred, stored, and processed by Plaid in accordancewith Plaid’s End User Privacy Policy.


Our digital properties link to other companies’ websites, many of which havetheir own privacy policies. Be sure to review the privacy policy on the websiteyou are visiting to understand their privacy practices—this Privacy Notice willnot apply to others’ digital properties.

‍Do Not Track Signals
Do Not Track (“DNT”) is an optional browser setting that allows you to expressyour preferences regarding tracking by advertisers and other third parties. Wedo not use technology that recognizes DNT signals from your web browser.

‍Accessing Your Information
You must notify us of any change in your personal information by updating your Compound account profile through our Services. Any changes will affect only future usesof your personal information.

Subject to applicable law, which might, from time to time, oblige us to storeyour personal information for a certain period of time, we will respect yourwishes to correct inaccurate information. Otherwise, we will hold your personalinformation for as long as we believe it will help us achieve our objectives asdetailed in this Privacy Notice.

You can ask us whether we are storing your personal information, and you canask to receive a copy of that personal information. Before sending you anypersonal information, we will ask you to provide proof of your identity. If youare not able to provide proof of your identity, we reserve the right to refuseto send you any personal information. We will respond as quickly as we can toyour requests for details of personal information we hold about you.

‍Information You Share Socially
Our Site, App and Services may allow you to connect and share your actions,comments, content, and information publicly or with designated individuals,friends, followers, etc. We are not responsible for maintaining theconfidentiality of any information you share publicly or through social media.

Our digital properties may include ways to interact and share using socialmedia, through features such as a “thumbs up” button, “share this” button, orinteractive mini-programs that run on our Site (“widgets”). These features maycollect information such as your IP address or the page you are visiting on ourSite and may set cookies to enable the feature to function properly. Socialmedia features can be hosted by a third party or hosted directly on our Site.Your interactions with these features are governed by the Privacy Notice of thesocial media company providing the feature. Please be mindful of your personalprivacy needs and the privacy needs of others, as you choose whom to connectwith and what to share and make public. We cannot control the privacy orsecurity of information you choose to make public or share with others. We alsodo not control the privacy practices of third parties. Please contact thosesites and services directly if you want to learn about their privacy practices.

‍Account Security
In consideration of your use of the Site, you agree to (a) provide accurate,current, and complete information as may be prompted by any registration formson the Site (“Registration Data”); (b) maintain the security of your passwordand identification; (c) maintain and promptly update the Registration Data, andany other information you provide to Compound, to keep it accurate, current,and complete; and (d) be fully responsible for all use of your account and forany actions that take place using your account.

‍How We Safeguard Your Personal Information
We have put in place security systems designed to prevent unauthorized accessto or disclosure of Personally Identifiable Information, and we take allreasonable steps to secure and safeguard this Information, including: Our Site’s password-protected     section requires users to give us unique identifiers such as their email     address; We employ a secure channel,     using Secure Sockets Layer (SSL) encryption, the standard for secure     Internet network connections, to protect information exchanged over the     Internet between your web browser and our servers; We provide access to our     databases containing Personal Information on a need-to-know basis only;     andWe use automated tools to monitor network traffic to identifyunauthorized attempts to upload information, change information, or otherwiseseek to gain unauthorized access to our systems.

Unfortunately, the transmission of information via the internet is notcompletely secure. Although we employ commercially reasonable,industry-standard methods to protect your personal information, we cannotguarantee the security of your personal information transmitted to the Site.Any transmission of personal information is at your own risk. We are notresponsible for circumvention of any privacy settings or security measurescontained on the Site.

‍Choices About How We Use and Disclose YourInformation
We aim to provide you with choices regarding the personal information youprovide to us. Users of our Site, App, and Service may therefore opt out ofsome communications from our Site or our partners. 

We have created mechanisms to provide you with the following control over your information:  Tracking Technologies and     Advertising. You can set your browser to refuse all or some browser     cookies, or to alert you when cookies are being sent. If you disable or     refuse cookies, please note that some parts of the Site may then be     inaccessible or not function properly. Emails from the Company. If we     have sent you a promotional or marketing e-mail, you may send us a return     e-mail asking to be omitted from future e-mail distributions or click the     “unsubscribe” link at the bottom of each non-transactional email. Please     note that you are not able to opt out of receiving communications about     your account or related transactions with us. From time to time, we may send     surveys, requests for feedback regarding user experience, and Site     operations or additional services from us or from our marketing partners,     including by telephone to cellular phone numbers or text messages, if you     have provided us with these numbers. The completion of surveys or requests     for feedback or acceptance of any offer is voluntary. If you do not wish     to receive these offers, surveys, or user feedback emails, please opt out     in any offer email received from us. Compound honors your privacy     preferences, and you may opt out of all data sharing with third party     advertisers by emailing us at support@compoundrealestatebonds.com 

‍California Privacy Rights
If you are a California resident, California law grants you the ability toreceive additional information regarding how we collect, use and share your“personal information” (as defined in the California Consumer Privacy Act(“CCPA”)), other than the personal information we collect in connection withproviding our services.

Depending on how you use our Site and services, we may collect the followingcategories of personal information about you, in addition to the information wecollect in connection with providing our services: Identifiers, such as name,     contact information, and Internet Protocol (IP) address Internet or other network     information, such as use and interaction with our Site, and browsing     history

‍Your California Privacy Rights – “CCPA Notice”
California law grants additional privacy rights to California residents. Inparticular, the California Consumer Privacy Act of 2018, as amended by theCalifornia Privacy rights Act of 2020  (CCPA) requires businesses todisclose, for the past 12 months, (i) the categories of personal informationcollected, (ii) the sources of the collected personal information, (iii) thepurposes for which the collected personal information is used, (iv) thecategories of personal information disclosed for a business purpose, and (v)the categories of any personal information sold or shared. We provide thesedisclosures in the following table. 

When we use the term “personal information” in this CCPA Notice,we mean information that identifies, relates to, describes, is reasonablycapable of being associated with, or could reasonably be linked, directly orindirectly, with a particular consumer or household.