General

REIFY, LLC (“REIFY” “us” or “we”) provides online tools to assist companies, potential investors, and others who are interested or involved in the acquisition, development, leasing, management, and financing of real estate and real estate projects. This privacy policy (our “Privacy Policy”) describes our data practices regarding Personal Information collected through online interfaces and properties (e.g., websites, https://100kmillionaires.com/, and mobile applications) (collectively, the “Site”). This Privacy Policy applies to all users and visitors to the Site (“you(r)”), but does not apply to Personal Information collected by third party websites or mobile apps not operated by REIFY

As a financial company, federal law (the Gramm-Leach-Bliley Act, or “GLBA”) also requires us to tell you how we collect, share, and protect your Personal Information. Please see the GLBA Appendix at the end of this Privacy Policy to learn more about how we treat your Personal Information under GLBA.

By accessing the Site and/or using our Site, you are consenting to our use of your Personal Information in accordance with this Privacy Policy. Further, your access to and use of the Site is subject to the REIFY Terms of Use

Information REIFY Collects About You

Personal Information You Provide

We use the term “Personal Information” to mean any information that could be used to identify you, including your name, address, email address, birth date, financial information, cell or land-line phone number, location, or any combination of information that could be used to identify you.

What Personal Information we collect from you depends on what services you choose to use and how you interact with the Site:

Site Visitors. We have structured our Site so that, as a casual site visitor, you may come to our Site and review selected information about our Site without registering. However, if you wish to become an Investor, then we require you to provide certain additional Personal Information.

Investors. If you choose to access our Site as an Investor, we require that you complete a registration form. An Investor is an individual who is over the age of 18 and has completed the registration process on the Site. Our registration forms will specify the information which you must provide in order to enjoy the particular features to which you wish to subscribe, which may include such items as (i) name; (ii) email address; (iii) phone number(s); (iv) mailing address; (v) social security number (for IRS tax reporting purposes); (vi) bank account number; and (vii) birth date. Our registration forms may additionally request information that you may, at your option, choose to provide or withhold. To the extent this additional information constitutes Personal Information, we will treat it in the manner specified in this Privacy Policy.

We may require each Investor to provide information designed to verify his or her identity. This information may include (i) information from a successfully completed electronic check transaction, (ii) a credit report, or (iii) other similar information designed to authenticate and confirm your identity or to otherwise comply with applicable law.

We also require each Investor to provide certain financial information. For example, we require that each Investor also provide Internal Revenue Service Form W-9 data, which includes your Social Security Number (or Taxpayer Identification Number, where applicable). We also require that Investors provide us with certain account and other payment information, such as information needed to make payments via ACH, wire, or electronic checks. Our registration process for Investors provides additional details on the types of payment information needed.

Users also may choose to upload media files such as videos, photos, text, and other content to the Site to share with REIFY and other users. When you upload this content, we may also collect metadata associated with these media files including date, time, location and device information. REIFY’s use of such content will be governed by our user-generated terms and conditions which are provided at the time of collection of such content

Location Data. We may collect your location information through our mobile applications by capturing the location (e.g. latitude/longitude) of your mobile device. If you have given the app permission to access your location, we may collect your device’s location even if you are not using the Service and store your location history. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to restrict the app’s access to your location data. Geolocation data may be used to enhance the Site, for example to offer additional functionality and information regarding your location in connection with the location of REIFY properties.

Automatically-Collected Information

Even if you do not register for an account on the Site, we may collect certain information automatically. For example, we may automatically receive and record in our system the following information:

  • your internet protocol (IP) address and location;
  • referrer URL;
  • the type and version of your web browser;
  • device identifiers including mobile advertising identifiers; and
  • your operating system.

We also record page views and other general statistical and tracking information. We use this data to help us administer and operate our Site, to better understand how our users access and interact with the Site, and for security and monitoring purposes.

We may send email messages that use a “click-through URL” linked to content on our Site. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked, simply do not click text or graphic links in the email.

Information Collected in the Past 12 Months. In the 12 months preceding the date this Privacy Policy was last updated, REIFY has collected Personal Information from users including payment information, personal contact information, business information, log-in credentials, usage details, and technical details. This information has not been disclosed or sold except as provided herein.

How We Use Your Personal Information

We use your Personal Information for the following business purposes:

  • to process transactions that you have authorized us to make;
  • to facilitate your activities with respect to our Site;
  • to contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests;
  • to verify and authenticate your identity, to help us ensure that the individuals who use the Site and Services are who they claim to be;
  • to prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including, for example, activities prohibited by the Anti-Money Laundering Act;
  • to help us operate our Site;
  • to deliver notices regarding your account;
  • to comply with IRS requirements and for tax reporting purposes;
  • to provide you with information, such as notices of investment opportunities via our Site or updates concerning investments that you have participated in;
  • to send you information we believe is relevant to you, such as news, bulletins, marketing materials, or other information;
  • to enforce this Privacy Policy and our Terms of Use;
  • to conduct user surveys and questionnaires; and
  • to comply with applicable law.

We use aggregated information to analyze the effectiveness of our Site, to improve our Site, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Site and the characteristics of visitors at our Site, and may share aggregated information with third parties, including advertisers. We may collect aggregated information through features of the software that support our Site, through cookies, and through other means described in this Privacy Policy.

To enable us to better understand the characteristics of our Investors and/or to provide services tailored to your needs, we may combine the Personal Information an Investor provides with certain automaticallycollected information that would not otherwise be personally identifiable. If we combine or link any automatically-collected, non-individually identifiable information with your Personal Information, the resulting combination will be treated as Personal Information under this Privacy Policy.

How We Share Personal Data

We do not disclose your Personal Information to unaffiliated third parties except as provided in this Privacy Policy, as follows:

Service Providers. To assist us in running our business and to perform certain services and functions, we may share your Personal Information with third-party providers (e.g., Firebase analytics and Stripe) of hosting, payment processing, transfer agent, email communication and customer support services, analytics, marketing, and advertising service providers, which provide integrated services to us as part of our product.

For users who choose to link their bank accounts, we may use third-party providers to facilitate the automatic connection with, and gather required transaction data from, your financial institution.

Affiliates. We may share information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with REIFY. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

For Legal Reasons. We may share your Personal Information to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, or to protect against fraud, illegal activity, or to otherwise protect REIFY against liability.

In Connection with a Corporate Transaction. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of REIFY or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share your Personal Information in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy.

For Safety & Security. We may reveal your Personal Information to third parties, including law enforcement agencies, in order to protect the safety and security of our users or of any third party.

Cookies, Pixel Tags, and Similar Technologies

A cookie is a small amount of data, often including a unique identifier, which is sent to your browser from a website and stored on your computer’s hard drive. We use both “session” cookies and “persistent” cookies, as follows:

Session cookies: We use session cookies to improve navigation on our Site and to collect aggregate statistical information. A session cookie expires when you close your browser. Because these cookies are strictly necessary to use the Site, you cannot refuse them.

"Persistent" cookies: Persistent cookies are bits of information that are placed on the hard drive of your computer and can remain for extended periods of time. Persistent cookies also enable us to provide enhanced, more personal features (such as showing or hiding notifications), and track and target the interests of our users to enhance the experience on our Site. The types of persistent cookies used on the Site are described in more detail below. You may set your browser so that it does not accept cookies, and you may also use the direct opt-out tools provided by the parties described below. If you do not enable or if you disable cookies, however, you may not be able to access certain personalized features of our Site.

We may also use so-called “pixel tags” – small graphic images (also known as “web beacons” or “singlepixel images”) – to tell us what parts of our website have been visited or to measure the effectiveness of marketing campaigns on our Site. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly on our Site. Pixel tags inform us whether emails have been opened, to help ensure that our messages are of interest to our users. We may tie the information gathered by pixel tags to our users’ Personal Information, in which case it will be subject to the terms of this Privacy Policy.

Feedback, Questionnaires and Surveys.

Our Site allows site visitors and Investors to participate in surveys and questionnaires, which from time to time we may post on the Site. We also encourage our users to provide feedback to us about our Site and our Site. You are free to choose whether you participate in these activities. We may ask that, in addition to providing your responses, you also provide us with your contact information. In these instances, we use any Personal Information you choose to provide to us in connection with these activities for the purposes for which you submit the information.

We aggregate information derived from survey and questionnaire information – with your Personal Information removed – for monitoring or improving the use and appeal of this Site (with no other obligation to you and, specifically, with no obligation to compensate you for these uses). You are not obligated to participate in any of these activities.

Links to Other Sites

This Privacy Policy applies only to Personal Information collected by our Site. Our Site contains links to other sites that are not owned or controlled by REIFY. REIFY is not responsible for the privacy practices of such other sites, and we encourage you to be aware when you leave our Site and to read the privacy statements of each and every web site that collects Personal Information.

Data Security

We have put in place commercially-reasonable security systems intended to prevent unauthorized access to or disclosure of Personal Information, and we take reasonable steps to secure and safeguard this Personal Information against loss, theft, and unauthorized use, disclosure, or modification. With that said, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf. For example, email sent to or from the Site may not be secure. Before submitting any Personal Information via the Site, please be aware of these inherent risks and understand that you do so at your own risk.

Data Retention

We keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is longer.

Your Choices

In general, you may browse the Site without providing Personal Information. However, if you choose not to provide certain Personal Information through our Site, we may not be able to provide certain services or process certain requests.

Depending on the functionality associated with the Site feature you are using, you may be able to update or delete certain of your Personal Information on the Site. Accordingly, at your request, we will take reasonable steps to remove your Personal Information from our databases. However, please note that:

  • we may not be permitted to delete your Personal Information completely, due to IRS and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions;
  • if you request deletion of your Personal Information, you may be unable to use certain features of the Site and any associated Services;
  • certain of your Personal Information may remain in our databases following the deletion of your account; and
  • we may not be able to remove de-identified, anonymous, or aggregate data from our databases. Any deletion requests may be sent to hello@nycegroup.co.

If you no longer wish to receive marketing emails from us, you can opt out of these communications by clicking on the “unsubscribe” link included in those emails, or by contacting us at hello@nycegroup.co. Please understand that you will not be allowed to opt-out of transactional notices or other legal and related notices concerning your relationship to the Site or your account.

Children’s Privacy

Our Site is not directed to children under the age of 13. We do not knowingly seek to collect or maintain Personal Information or other information from children under the age of 13. We will use commercially reasonable efforts to delete any Personal Information or other information later determined to be provided by a child under the age of 13. Use of the Site by children under the age of 13 is not permitted. If you become aware that a minor has provided Personal Information through our Site, please email us at support@100Kmillionaires.com.

Changes to This Privacy Policy

We reserve the right to alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Site. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and share Personal Information.

Users Outside the United States

Consent to US Processing. If you are a resident of the European Economic Area (EEA), in order to provide our Site, products and services to you, we may send and store your Personal Information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your Personal Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Information. Where such transfers occur, we take reasonable steps to protect your information in any such country to the extent feasible under applicable law. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of Personal Information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

GDPR Disclaimer. The Site is not intended to be used by individuals residing in the European Union, is not advertised or directed towards individuals residing in the European Union. The provisions contained in this Privacy Policy may or may not be compliant with European Union law, including its General Data Protection Regulation ("GDPR"), or affiliated or similar laws. However, we make good faith efforts to comply with GDPR, and to that end we expressly provide that European Union residents have a right to consent to how REIFY uses your data. Above, we have described the data points we collect and how this information may be used. We never abuse your information. Under GDPR you have the right to ask for all the data collected on you by written request. Your data is stored in a secure database. It will take up to 72 hours to retrieve and send you collected data. The data will be provided in the form on a spreadsheet and sent via personal email. Your right to be forgotten refers to your right to have your information wiped from our database. If you wish for your information to be removed please Contact Us and we will confirm your information is removed via email within 72 hours.

California Residents

If you live in California, you have the right to: (1) request that we disclose what Personal Information we collect, use, disclose, and sell; (2) request deletion of Personal Information; (3) opt-out of the sale of Personal Information; and (4) not receive discriminatory treatment by REIFY for exercising these rights. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To make a request on your behalf, an authorized agent may Contact Us in writing with proof of your written and signed permission to do so. Please note, we may require you to verify your identity and confirm that you gave permission.

Requests to Know. California residents have the right to request that we disclose the following information:

  • Specific Personal Information REIFY has collected about you;
  • Categories of Personal Information REIFY has collected about you, disclosed about you for a business purpose, or sold;
  • Categories of sources from which the Personal Information is collected;
  • Categories of third parties with whom REIFY shares or to whom REIFY sells Personal Information; and
  • The business or commercial purpose for collecting and selling Personal Information.

To make such a request, please Contact Us by email, telephone, or submit the request through your REIFY account. In order to verify your request, REIFY may require you to provide additional information to confirm the identity of the consumer.

Requests to Delete. California residents have the right to request that we delete Personal Information about you that we collected and maintain, subject to certain exceptions. To make such a request, please Contact Us by email, telephone, or submit the request through your REIFY account. In order to verify your request, REIFY may require you to provide additional information to confirm the identity of the consumer. Once we verify your request, we will delete and direct our service providers to delete your Personal Information, unless an exception applies.

Opt-Out of the Sale of Personal Information. California residents have the right to opt-out of the sale of your Personal Information. To make such a request or to opt-out , please Contact Us by email.

“Shine the Light” Request. California residents may also have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please Contact Us.

Nevada Residents

Nevada residents may have the right to opt-out of the sale of Personal Information we have collected or will collect. To make such a request, please Contact Us.

How We Respond to “Do Not Track” Signals

Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, the practices of our Site or Services, or your dealings with our Site or Services, please contact us at:

REIFY, LLC 626, 1st Ave, Apt E7A New York, NY 10016 1-646-465-2248 support@100Kmillionaires.com