This Privacy Policy discloses the privacy practices of Centra Capital Partners, LLC (“CCP”, “us,” or “we”). We are committed to protecting your privacy. This policy describes the types of information we may collect from you or that you may provide when you visit our website, how we collect that information, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

 
CCP’s website is located at https://www.centracapitalpartners.com (its "Website") and is not intended for individuals less than the age of eighteen. CCP does not knowingly collect data relating to individuals less than the age of eighteen.

 
This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.

It does not apply to information:

• Provided by you not through the Website or through any other means, including through any other website operated by 

Company or any third party

• Collected by any third party including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Your access to and use of the website is conditional upon your acceptance of and compliance with this Privacy Policy. This Privacy Policy applies to everyone, including, but not limited to visitors, users, and others, who wish to access or use the Website. By accessing or using the website, you agree to be bound by this Privacy Policy. If you disagree with any part of the Privacy Policy, then you do not have our permission to access or use the Website.

1. Information We Collect
2. How We Use Your Information
3. How We Collect Your Information
4. How We Share Your Information
5. Sale of Personal Information
6. Retention of Your Personal Information
7. Your Choices
8. Transfer of Your Personal Information
9. Security of Your Personal Information
10. Links to Other Websites
11. Children’s Privacy
12. Changes to this Policy
13. California Residents

Data Controller
CCP is the data controller.

 
Questions, comments, and complaints about our data practices can be submitted to:
Centra Capital Partners, LLC
11460 Robinson Drive NW
Minneapolis, MN 55433

Telephone Number: (763) 230-4001

Information We Collect

We may collect several types of information from and about users of our Website, including:

• Personally Identifiable Information (“Personal Information”). Personal Information includes information that is reasonably capable of being associated with or could reasonably be linked to a particular consumer or household.
• Public Information. Public information is information that is reasonably available to the public.
• De-identified or Aggregated Information. This is information that is about you, but that does not individually identify you.
• Usage Data. This includes information about your internet connection, the equipment you use to access our Website, and usage details.

When you use our Website, we, or certain third-parties on our behalf, may collect the following categories of Personal Information:

• Identity/Contact Data, such as your name, e-mail address, mailing address, physical address, or phone number(s).
• Internet/Device Data, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, mobile application, or digital advertisement. This may include the following categories of information, which we may automatically collect when you use our Website:  

              o Usage Data, including, but not limited to, information about how you use our Website, what pages you view, the                    number of bytes transferred, the links you click, the materials you access, the date and time you access the                            Website, the website from which you linked to one of our Website and other actions taken within the Website; and
              o Technical Data, such as your Internet Protocol (IP) address, your device ID, your browser type and capabilities                       and language and your operating system. An “IP address” is a unique number that is automatically assigned to                       your computer when you connect to the Internet. It is used to identify your computer’s “location” in cyberspace,                   so that the information you request can be delivered to you.

AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect usage data.

 
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.

 
When you access the Website 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 Website or when you access the website by or through a mobile device.

 
The information we collect automatically is only statistical data and does not include Personal Information, we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.

TRACKING TECHNOLOGIES AND COOKIES

 
We use cookies and similar tracking technologies to track the activity on our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to provide you with a better website. A cookie in no way gives us access to your computer or any information about you, other than the information you choose to share with us. 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 Website may use cookies.
• Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html
• Web Beacons. Certain sections of our Services 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 us, 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 whether 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 information.

 
We also use a tool called “Google Analytics” to collect information about your use of the website. Google Analytics collects information such as how often users access the website, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Website and services. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

How We Use Your Information

Personal Information is collected solely for the purpose of providing accredited investors with access to investment opportunities in real estate. The information provided remains part of our records until we determine the information is no longer needed, or we are required by law to delete such information. We will collect the minimum amount of data necessary to provide you with access to our services and investment opportunities.

We may use your Personal Information for one or more of the following business purposes:

• To provide and maintain our services to you, including to monitor your use of our services.
• To fulfill or meet the reason you provide the information. For example, if you provide information necessary to fund a transaction, we will use that information to process your payment.
• For the performance of a contract, including the development, compliance and undertaking of the purchase contract for the products, items or services you have inquired about or of any other contract with us through the Website.
• 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 Information 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.
• To ensure security and integrity to the extent personal information is reasonably necessary and proportionate to these purposes.
• To respond to law enforcement requests and as otherwise permitted by applicable law, court order, or governmental regulations;
●
• To verify or maintain the quality or safety of the services or account, or to prevent fraud.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 
How We Collect Your Information
We collect most of this Personal Information directly from our clients when you provide it to us directly on our Website, from activity on our Website, as well as from you by telephone, written correspondence through the mail, email or fax, or other information available online. However, we may also collect information: 

• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From a third party with your consent (e.g., your authorized representative, and/or attorney, or our business partners). If you do not provide your consent for a third party to share your information with us, we may not be able to provide the services to you, or they may not be as effective.

How We Share Your Information

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 services, or 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 and have a privacy policy of their own, which is at least as restrictive as this one. 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 Your consent: We may disclose your Personal Information for any lawful purpose with your consent.

CCP may share personally identifiable information it collects with its employees who need to know that information to service your account. Except as provided below, CCP does not share or disclose any personally identifiable information to any company or marketing group external to CCP. CCP may share your personal information with third parties to the extent it is reasonably necessary to manage or service your account, verify employment, determine location, process payment, fulfill a transaction, provide customer service, or as otherwise authorized by law.

Further, CCP may disclose personally identifiable information (i) to another entity with which CCP enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, (ii) to a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or in connection with litigation brought against, or on behalf of, CCP, where appropriate, (iii) to a third party if determined by CCP in its sole judgment that such disclosure is appropriate to protect the life, health, or property of CCP or any other person or entity, all in compliance with applicable law, (iv) to third parties as authorized or designated by you, or (v) to conduct any other legitimate business activity not otherwise prohibited by law. The foregoing is not intended to obviate or displace any legal obligations or duties applicable to CCP.

Sale of Personal Information

We do not sell and will not sell your Personal Information.

Retention of Your Personal Information

CCP will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information 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.

CCP 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.

Your Choices

CCP offers you certain choices in connection with the information, including Personal Information it collects from you, including:

Your CCP Account: You may review, update and correct your contact information, including your telephone number and email address by contacting our office.

Tracking Technologies: 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 this site may then be inaccessible or not function properly.

Promotional Offers from CCP: If you do not wish to have your email address/contact information used by CCP to promote our products or services, you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the CCP as a result of a product purchase, warranty registration, product service experience or other transactions.

If you have any questions regarding any of these choices, please contact CCP.

Transfer of Your Personal Information

Your information, including Personal Information, 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 Information 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.

Security of Your Personal Information

CCP has implemented administrative, physical, and technical security safeguards to protect against the unauthorized release of or access to Personal Information. We employ internal and external system safeguards designed to protect confidentiality and security of Personal Information.

The confidentiality of any communication or material transmitted to or from CCP via the website or via e-mail cannot be, and is not, guaranteed. You acknowledge that the technical processing and transmission of the Website’s content may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to confirm and adapt to technical requirements of connecting networks or devices.

We will collect the IP Address of all visitors to the CCP website for internal security and other proprietary purposes. We do not release this data outside of our corporate team nor utilize the data other than for internal purposes.

Links to Other Websites

Our Website 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. You should exercise caution and look at the privacy statement applicable to the website in question.

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

Children’s Privacy

This Website is intended for use by a general audience and does not offer services to children. No one under age 18 may provide any information through the website. We do not knowingly collect Personal Information from children. If you are under 18, do not use or provide any information on this website. If you believe your minor child submitted information on this Website, please contact us using the information below and we will erase such information upon request.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us
If you have any questions about this Privacy Policy, You can contact us:
● By email: [email protected]
● By visiting this page on our website: https://centracapitalpartners.com/contact
● By phone number: 763-230-4001

CALIFORNIA CONSUMER PRIVACY ACT NOTICE FOR CALIFORNIA RESIDENTS

This California Privacy Notice is provided as a supplement to our CentraCapitalPartners.com Privacy Policy and includes information on how California residents can exercise their rights under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) (collectively, “California Privacy Laws”). We reserve the right to change this California Privacy Notice from time to time. Changes shall become effective on the date they are posted.

 
We may collect and may have collected the following categories of Personal Information from users within the last 12 months. Inclusion of a category indicates that we may collect some information in that category. It does not mean that we collect all information listed in that category in all situations. Any CCPA categories not listed in the table below have not been collected in the 12 months prior to the Effective Date of this Policy.

Categories of Personal Information

Examples of Specific Types of Personal Information Collected

How Collected

Purpose

Identifiers

A real name, alias, postal address, email address, and telephone number(s)

From you

(a) Necessary to provide the services

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

(d) Prevent fraud

Categories of personal information described in subdivision (e) of Section 1798.80 (California Customer Records statute, Cal. Civ. Code 1798.80(e))

Name and address

From you

(a) Necessary to provide the services

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

(d) Prevent fraud

Internet or other electronic network activity information

information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

From you, automatic collection

(a) Necessary to provide the services

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate business interests

Your Rights

The CCPA provides California consumer with certain rights regarding their personal information, as described below.

• Right to request to access personal information – You may submit a verifiable request for access to your personal information that we collected about you, subject to certain exceptions. This may include the categories and specific pieces of information collected, the sources of that information and the business or commercial purpose for the collection or disclosure of that information.
• Right to request correction of personal data we hold about you - You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate or incomplete, subject to certain exceptions.
• Right to request deletion of personal information - You have the right to request that we delete your personal information, subject to certain exceptions. For instance, state and federal law may prohibit us from deleting personal information, which CCP will disclose to you.
• Right to object to processing of your personal data – Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you may object to processing of such data. You may also object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Right to request restriction of processing of your sensitive personal data - To the extent your sensitive personal information (as that term is defined under California Privacy Laws) is used to infer characteristics about you, you have the right to direct us to stop such processing of your sensitive personal information for such purposes. CCP does not use your sensitive personal information to infer characteristics about you or limits its use to purposes authorized by CPRA Section 1798.121(a).
• Right to request the transfer of your personal data to you or to a third party - We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent at any time where we are relying on consent to process your personal data – however, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Notice regarding Automated decision making and profiling - 'Automated Decision Making' refers to credit decisions regarding consumer lending terms or conditions predicated solely on the creditor’s automated processing of personal data. This means credit decisions may be made by a creditor, for example, using software code or an algorithm which does not require human intervention. We do not extend credit or make credit decisions for any person and we do not use your personal data as part of any such automated decision making or profiling when servicing your account.
• Right to non-discrimination - You have the right to be free from discrimination for exercising your rights under the CCPA.
• Right to use of an authorized agent – You can designate an authorized agent to make any of these requests by providing your express written authorization. We must be able to verify your identity and the authorization must include the authorized agent’s name, address, telephone number, and email address (for providing the personal information collected or to respond to a request for deletion).

Exercising Your Rights

If you wish to exercise any of these options, please contact CCP by doing one of the following:

• By email: [email protected]
• By visiting this page on our website: https://centracapitalpartners.com/contact
• By phone number: 763-230-4001

If you choose to contact directly by e-mail, telephone or through the Website, you will need to provide us with:

• Enough information to identify you [e.g., your full name, address and customer or matter reference number];
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. To prevent anyone other than you, or your authorized agent, from exercising the right to know or the right to delete with respect to your personal information, we follow procedures to verify your, or your agent’s, identity. These procedures seek to confirm that the person making a request is the person about whom we have collected personal information or that person’s authorized agent. The verification procedures involve matching data points that you provide with your request against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. We will use information you provide in your completed request form to verify your identity, and we may request additional information if necessary to complete the verification process.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you would like to appeal of our decision with respect to your exercise of the above options, an appeal may be sent to the data controller using the same process for submitting initial requests. A response to an appeal may take up to 60 days, at which time CCP shall respond to your request.