Privacy Policy

1. Information We Collect

We collect the following categories of personal information:

• Identity information: When offerings open, we will collect your full legal name, date of birth, tax identification number (Social Security Number or EIN, an Employer Identification Number used by businesses) as required by federal securities law, and a government-issued photo ID.
• Contact information: Email address, phone number, mailing address.
• Waitlist sign-up: Your email address, whether you want information about a possible offering, and, if you choose, a non-binding investment interest range. Your name, state, and phone number are optional. We record which page you signed up from. We don't ask for your street address when you join the waitlist.
• Homeowner waitlist: Your email address.
• Support messages: Your name, email, subject and message, used only to reply to you.
• Rental-owner inquiries: Your name, contact details and information about your property. We use this only to discuss a possible property with you, and we send you one email to confirm we received it.
• Partner inquiries: If you are a property manager or real estate agent who contacts us through our partners page: your name, contact details, company, role, the state where you mainly work, and any note you add. We use this only to discuss working together, and we send you one email to confirm we received it.
• Financial information: When offerings open, we will collect your annual income, net worth, bank account details, investment history, and accreditation status (whether you qualify as an accredited investor, generally someone with $200,000+ income or $1 million+ net worth).
• Wallet information: Arbitrum (Ethereum-compatible) wallet addresses (the public ID of a digital wallet) used to connect to the Platform.
• Usage data: IP address (your device's internet address), browser type, pages visited, timestamps, and device identifiers.

Collection of identity and financial information is required by federal Regulation Crowdfunding (Reg CF), the law that governs small investment offerings, and by anti-money laundering laws, which help stop criminals from hiding illegal money. This information is used solely for compliance and verification purposes.

2. How We Use Your Information

• To verify your identity and complete KYC (Know Your Customer, confirming who you are) and AML (Anti-Money Laundering) compliance.
• When offerings open, to process investment transactions and issue security tokens (digital tokens that are regulated investments).
• To determine eligibility and enforce Reg CF investment limits.
• When offerings open, to communicate about your investments, account status, and Platform updates.
• To comply with federal and state securities regulations and reporting requirements.
• To improve the Platform, prevent fraud, and ensure security.

3. Third-Party Sharing

We share personal information only as necessary for the following purposes:

• SEC-registered intermediary: When an offering opens, investment data will be shared with the SEC-registered intermediary conducting it (a regulated investment platform registered with the Securities and Exchange Commission), as required by Regulation Crowdfunding.
• Analytics and advertising (Google Analytics, Meta Pixel): Usage data is shared with Google and Meta as described in Section 8.
• KYC/AML provider (Persona): Identity information is transmitted to Persona, our identity verification partner, for compliance checks. Persona's privacy policy is available at withpersona.com.
• Cloud infrastructure (Supabase): Account data is stored on Supabase, which provides encrypted database hosting.
• Email provider (Resend): Email addresses are shared for transactional communications, and to forward rental-owner and partner inquiries to our team.
• Payment processing (Stripe): Payment and bank account information is processed by Stripe, a PCI-DSS compliant payment provider, meaning it meets the card industry's data security standard. Stripe's privacy policy is available at stripe.com/privacy.
• Law enforcement and regulators: We may disclose information when required by law, subpoena (a legal order to hand over information), or regulatory inquiry.

We do not sell personal information to third parties for marketing purposes.

4. Data Retention

We retain personal information for as long as your account is active and for a minimum of five (5) years after your last transaction, as required by federal securities record-keeping rules. KYC documentation is retained for a minimum of five years after the account is closed. You may request deletion of non-regulatory data (data the law does not require us to keep) by contacting us.

5. Data Security

We implement industry-standard security measures including encryption in transit (TLS, which scrambles data as it travels between your device and our servers) and at rest (while stored), access controls, and regular security audits. However, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security of your data.

Smart contract interactions (actions handled by programs that run on the blockchain) and token transfers are recorded on the Arbitrum blockchain, a public digital ledger, and are publicly visible by design. Wallet addresses associated with your account may be visible on the blockchain.

6. Your Rights

Depending on where you live (your jurisdiction), you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate information.
• Deletion: Request deletion of data not required for regulatory compliance.
• Portability: Request your data in a machine-readable format (a file a computer can read).
• Opt-out: Unsubscribe from non-essential communications at any time.

7. California Privacy Rights (CCPA, the California Consumer Privacy Act)

If you are a California resident, you have the right to know what personal information is collected, request its deletion, and opt out of the sale of personal information. BaseLots does not sell personal information. To exercise your rights, contact us at the address below.

8. Cookies and Tracking

We use essential cookies (small files a website stores in your browser) for authentication and session management, such as keeping you signed in. We also use the following analytics and advertising tools on this website:

• Google Analytics (Google LLC): measures how visitors use the site, such as pages viewed, approximate location, device and browser type, and events like joining the waitlist. It uses cookies and similar identifiers. You can opt out with the Google Analytics Opt-out Browser Add-on (tools.google.com/dlpage/gaoptout) or by blocking cookies.
• Meta Pixel (Meta Platforms, Inc.): records page views on this site so we can measure and improve our ads on Facebook and Instagram and build advertising audiences. Meta may link this activity to your Meta account under its own privacy policy. You can manage this in your Facebook ad preferences and by blocking third-party cookies.

These tools receive technical information such as your IP address, browser details, and the pages you visit. We do not send them the contents of the waitlist form (your email, name, state, phone number, or investment interest range) or the rental-owner or partner forms. You may disable non-essential cookies in your browser settings without affecting core functionality.

9. Children's Privacy

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors.

10. Contact