Privacy Policy

1. Scope

This Policy applies to website visitors, prospective investors, verified accredited investors participating in offerings made under Rule 506(c) of Regulation D promulgated under the Securities Act of 1933 (the "Securities Act"), and other individuals who communicate with us.

2. Information We Collect

a. Information you provide.

• Identity and contact data: full legal name, email address, mobile phone number, mailing address, date of birth.
• Investor profile data: state of residence, citizenship, employer, source of funds, investment experience, beneficial ownership information.
• Accreditation verification data: financial statements, tax returns, brokerage and bank statements, IRS forms, credit reports, and written confirmations from licensed attorneys, certified public accountants, registered broker-dealers, or registered investment advisers — as required by Rule 506(c) and SEC guidance to take "reasonable steps to verify" accredited investor status.
• KYC/AML data: government-issued identification, Social Security Number or Taxpayer Identification Number, and information required under the USA PATRIOT Act, the Bank Secrecy Act, and OFAC sanctions screening.
• Transaction data: subscription amounts, wire/ACH instructions, bank account information held in escrow, distribution preferences.
• Communications: messages you send us, support requests, and SMS opt-in records (including timestamp and consent text).

b. Information collected automatically.

• Device and usage data: IP address, browser type, operating system, referring URLs, pages viewed, and session timestamps.
• Cookies and similar technologies used to maintain sessions, remember preferences, and measure site performance.
• Advertising measurement: the Meta Pixel (Meta Platforms, Inc.), the LinkedIn Insight Tag (LinkedIn Corporation), the TikTok Pixel (TikTok Pte. Ltd.), and the X Pixel (X Corp.) record page visits and device/browser identifiers so we can measure advertising performance and show relevant ads to past visitors on Facebook, Instagram, LinkedIn, TikTok, and X. These tools do not load for visitors in the EEA, UK, or Switzerland. You can limit interest-based ads in your Meta, LinkedIn, TikTok, or X ad preferences or through your browser's cookie settings.

c. Information from third parties.

• Accreditation and identity verification vendors, escrow agents, transfer agents, broker-dealers, payment processors, and public records databases.

3. How We Use Information

• Determine eligibility to participate in a 506(c) offering and verify accredited investor status.
• Comply with federal and state securities laws, anti-money laundering (AML), know-your-customer (KYC), tax reporting (e.g., IRS Forms 1099, K-1, W-9, W-8), and sanctions obligations.
• Process subscriptions, distributions, refunds, and investor communications.
• Operate, maintain, secure, and improve the Services.
• Send transactional messages (account, security, offering, and tax notices) and — only with your express consent — marketing or promotional communications.
• Detect, prevent, and respond to fraud, abuse, and security incidents.

4. Legal Bases (where applicable)

Where required by law, we process personal information based on (i) your consent, (ii) the performance of a contract with you, (iii) compliance with legal obligations (including the Securities Act, the Investment Company Act of 1940, the Bank Secrecy Act, and the Internal Revenue Code), and (iv) our legitimate interests in operating and securing the Services.

5. How We Share Information

We disclose personal information to:

• Service providers, including accreditation verification providers, identity/KYC vendors, escrow and paying agents, transfer agents, fund administrators, auditors, legal counsel, cloud hosting, analytics, and email/SMS delivery vendors.
• Affiliated entities, sponsors, and special purpose vehicles formed to hold the underlying short-term rental properties.
• Regulators, self-regulatory organizations, and law enforcement when required by subpoena, court order, or applicable law (including SEC filings such as Form D).
• Successors in connection with a merger, acquisition, financing, or sale of assets.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

6. SMS / Text Messaging

We collect your mobile phone number so we can send you text-message alerts that you specifically request. If you opt in, you consent to receive recurring automated SMS messages from airEquity at the mobile number you provide.

• Message types: account activity, security and one-time verification codes, new property offerings, funding and subscription confirmations, distribution and tax-document notices, and other investor-service updates.
• Message frequency: up to 6 messages per month; frequency may vary based on account activity.
• Rates: message and data rates may apply according to your wireless plan.
• Opt-out: reply STOP to cancel SMS alerts at any time. Reply HELP for help. Opting out of texts does not close your investor account or stop other communications you have agreed to (such as email).
• No sharing for marketing: your phone number and opt-in record are not sold or shared with third parties for their own marketing purposes.
• Consent is not a condition: agreeing to receive text messages is not required to create an account, invest, or use the Services.
• Carriers: carriers are not liable for delayed or undelivered messages.

7. Data Retention

We retain personal information for as long as necessary to provide the Services and to satisfy recordkeeping obligations under the Securities Act, the Securities Exchange Act of 1934, FINRA rules (where applicable), the Bank Secrecy Act, IRS rules, and other applicable law — generally a minimum of five (5) years after the termination of your investor relationship, and longer where required.

8. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, role-based access controls, and vendor due diligence. No method of transmission or storage is 100% secure.

9. Your Rights

Depending on your state of residence (including California, Colorado, Connecticut, Virginia, and Utah), you may have the right to access, correct, delete, or port your personal information, to opt out of certain processing, and to appeal a denial of a request. To exercise these rights, email privacy@air-equity.com. We may need to verify your identity before responding. Certain information must be retained to comply with securities and tax laws and cannot be deleted.

10. GLBA Notice

Because airEquity offers securities, the Gramm-Leach-Bliley Act may apply to certain non-public personal information ("NPI"). We do not disclose NPI to nonaffiliated third parties except as permitted by law (e.g., to service providers, in response to legal process, or with your consent).

11. Children

The Services are intended for adults age 18 or older. We do not knowingly collect personal information from children under 13.

12. International Users

The Services are operated from the United States and are intended for U.S. persons. If you access the Services from outside the U.S., you consent to the transfer and processing of your information in the United States.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with a revised "Last updated" date and, where appropriate, notified to you by email.

14. Contact

airEquity Holdings, LLC
Email: privacy@air-equity.com