Privacy policy

PSFNetwork Inc.

Privacy Policy

Effective date: 06/01/2026

1.  Overview

PSFNetwork Inc. ("PSFNetwork," "we," "us," or "our") operates a technology platform that facilitates access to real estate investment opportunities structured through series limited liability companies. Because our Services involve the collection of financial, identity, and investment-related information — including information gathered to satisfy securities regulatory requirements — we take privacy seriously and want to be transparent about how we handle your data.

This Privacy Policy describes the categories of information we collect from people who use our website, mobile application, and related services (together, the "Services"), the legal bases and purposes for which we process that information, when and with whom it is shared, and what rights you have with respect to your data. It applies to all users and visitors, including registered investors, prospective investors, and people who simply browse our platform.

We may update this Policy from time to time. When we do, we will revise the effective date above and, for material changes, notify you by email or by posting a notice on our website. Continued use of the Services following any update constitutes acceptance of the revised Policy.

2.  Information We Collect

Account and Registration Data. When you create an account or register to use the Services, we collect the information you provide directly, including your full legal name, email address, residential address, telephone number, date of birth, and citizenship status. We may also collect employment information where relevant to investor suitability assessments.

Identity Verification and Compliance Data. Because our Services facilitate securities offerings subject to federal securities laws, we are required — directly and through our registered broker-dealer partners — to collect and verify information necessary for anti-money laundering ("AML"), know-your-customer ("KYC"), and investor eligibility purposes. This includes government-issued identification documents, taxpayer identification numbers or social security numbers, proof of address, accreditation status documentation, and responses to investor suitability questionnaires. This information is collected and processed in accordance with applicable securities laws, including Regulation A under the Securities Act of 1933, as amended.

Investment and Transaction Data. If you participate in an offering made available through the Services, we collect information related to your investment, including subscription amounts, payment method details, banking information used for electronic fund transfers, and records of distributions and returns. We also maintain records of communications between you and PSFNetwork in connection with your account and investments.

Usage and Device Data. When you visit or interact with our Services, certain information is collected automatically, including your IP address, browser type and version, operating system, device identifiers, referring URLs, pages visited, click paths, time spent on pages, and similar usage data. This information is generally non-identifying, but if we associate it with a specific individual, we treat it as personal data.

Mobile App Data. If you access our Services through a mobile application, we and our service providers may collect app usage data, including the dates and times your device connects to our servers, mobile advertising identifiers, and information about the features you use.

Communications. We collect the content of messages, emails, and other communications you send to us, as well as responses to surveys or questionnaires we send to you.

3.  How We Process Your Information

We process the information we collect for the following purposes:

  • Operating and improving the Services, including account management, technical support, and product development;

  • Verifying your identity and eligibility to participate in securities offerings, including KYC/AML screening and accreditation verification, as required by applicable securities laws and by our registered broker-dealer partners;

  • Processing subscriptions, electronic fund transfers, distributions, and other investment-related transactions;

  • Complying with our legal and regulatory obligations, including reporting obligations under Regulation A, FINRA requirements applicable to our broker-dealer partners, and applicable state and federal securities laws;

  • Communicating with you about your account, investments, tax documents, regulatory disclosures, and material platform updates;

  • Sending marketing and promotional communications about new offerings, features, and other opportunities (where you have not opted out);

  • Detecting, investigating, and preventing fraudulent, unauthorized, or unlawful activity;

  • Personalizing your experience and delivering content we believe will be relevant to you; and

  • Analyzing platform usage and user behavior through analytics tools to improve the Services.

4.  Legal Basis for Processing

Where applicable law requires us to identify a legal basis for processing personal information, we rely on the following:

Contractual Necessity. We process certain information because it is necessary to provide the Services you have requested, including creating and managing your account, processing investment subscriptions, and administering your investor profile. Without this processing, we cannot deliver the Services.

Legal Obligation. We process certain information because we are required to do so by law. This includes processing necessary to comply with AML and KYC obligations, investor verification requirements under applicable securities laws, mandatory recordkeeping obligations imposed by the SEC and FINRA, and tax reporting requirements.

Legitimate Interests. We process certain information based on our legitimate interests in operating and improving the Services, detecting and preventing fraud and security incidents, analyzing platform performance, and communicating relevant product and service information to users. We only rely on legitimate interests where those interests are not overridden by your privacy rights.

Consent. Where we send marketing communications or use non-essential cookies and tracking technologies, we do so on the basis of your consent. You may withdraw consent for marketing communications at any time by following the unsubscribe instructions in those messages or by contacting us at support@psfnetwork.com. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

5.  Cookies and Digital Tracking Technologies

Cookies. Our website uses cookies — small text files placed on your device — to recognize returning visitors, remember preferences, enable interactive features, analyze traffic, and serve relevant advertising. By continuing to use the Services, you consent to our use of cookies as described in this Policy. You may disable cookies through your browser settings, but doing so may affect the functionality of the Services.

Analytics Services. We use third-party analytics services that collect and analyze information about how users interact with the Services, including pages visited, time spent on pages, and traffic sources. These providers may offer opt-out tools through their own platforms. We encourage you to review the privacy policies of any analytics providers whose tools may be active on the Services.

Pixel Tags and Web Beacons. We may use pixel tags and web beacons to track user actions across the Services, including in emails, to measure the success of marketing campaigns and analyze usage patterns.

Third-Party Advertising. We work with third-party advertising partners who may place cookies on your browser to serve you interest-based advertisements. To opt out of interest-based advertising, visit https://optout.aboutads.info or https://optout.networkadvertising.org.

Mobile Identifiers. On mobile devices, we and our partners may use mobile advertising identifiers to provide and personalize the Services. You may limit the use of such identifiers through your device settings: on iOS, go to Settings > Privacy > Advertising > Limit Ad Tracking; on Android, go to Google Settings > Ads > Opt out of interest-based advertising.

Do Not Track. Our Services do not alter their data practices in response to browser Do Not Track signals. For more information, visit https://allaboutdnt.com/.

6.  Data Security

We implement physical, electronic, and administrative safeguards designed to protect your information from unauthorized access, use, disclosure, alteration, and destruction. These measures include encryption of stored data, transmission of data over HTTPS, and access controls that restrict employee and contractor access to personal information to those with a legitimate need to process it.

Your account is protected by a password. You are responsible for keeping your credentials confidential and for taking reasonable precautions to protect your account, including logging out when accessing the Services from shared devices. If you believe your account has been compromised, contact us immediately at support@psfnetwork.com.

Despite our efforts, no security system is impenetrable, and we cannot guarantee the absolute security of your information. In the event of a security incident involving Personal Information, we will provide notice as required by applicable law. By using the Services, you acknowledge and accept the inherent risk of data transmission and storage.

7.  Disclosure and Sharing of Information

We do not sell your personal information. We may share your information in the following circumstances:

Broker-Dealer Partners. In connection with securities offerings made available through the Services, we share personal and identity information with one or more registered broker-dealer partners for the purpose of performing AML/KYC checks, investor verification, subscription processing, and related regulatory compliance. These partners use the information solely to perform these functions on our behalf and in accordance with applicable law.

Payment and Escrow Service Providers. We share information necessary to process payments and administer escrow accounts with one or more payment and escrow service providers engaged in connection with offerings made available through the Services. Such providers receive only the information required to perform these functions and are contractually prohibited from using it for other purposes.

Transfer Agent. We share investor information with one or more registered transfer agents appointed in connection with a securities offering, for the purpose of maintaining ownership records and administering investor accounts.

Affiliates. We may share information with PSFNetwork Holding LLC, PSFNetwork MasterSeries LLC, our parent entities, subsidiaries, affiliated issuers, series issuers, and other affiliates in connection with the operation of the Services and securities offerings.

Technology and Service Providers. We work with vendors who provide hosting, database management, identity verification, customer support, analytics, and other operational services. These vendors may access personal information only as necessary to perform services on our behalf and are contractually required to protect it.

Business Transfers. If PSFNetwork undergoes a merger, acquisition, reorganization, or sale of all or substantially all of its assets, your information may be transferred to the acquiring entity. We will notify you of any such transfer where required by applicable law.

Legal Requirements and Protection of Rights. We may disclose your information when we believe in good faith that disclosure is necessary to comply with applicable law, respond to legal process, protect the safety of any person, detect or prevent fraud or security issues, or enforce our rights and agreements.

8.  Securities Regulatory Obligations

Because PSFNetwork facilitates securities offerings subject to federal and state securities laws, certain uses and disclosures of your information are required by law and are not subject to your consent or opt-out choices. Specifically:

  • Regulatory Reporting. We are required to file periodic reports with the U.S. Securities and Exchange Commission ("SEC") in connection with our Regulation A offerings, including annual reports on Form 1-K, semi-annual reports on Form 1-SA, and current reports on Form 1-U. While these reports generally do not include individual investor personal information, aggregate data about the offering and investor base may be included.

  • Regulatory Examinations. The SEC, FINRA, state securities regulators, and other governmental authorities may have access to your information in connection with regulatory examinations, investigations, or proceedings, without prior notice to you and regardless of your privacy preferences.

  • Broker-Dealer Compliance. Our registered broker-dealer partners are independently subject to regulatory obligations — including AML/KYC, anti-fraud, and investor suitability requirements — that require the collection, retention, and in some cases reporting of investor information. These obligations are imposed by federal law and applicable self-regulatory organization rules.

  • Mandatory Retention. Certain investor records, transaction records, and compliance documentation are subject to mandatory retention periods imposed by applicable securities laws and regulations and may not be capable of deletion in response to a user request during the applicable retention period.

9.  Blockchain and Distributed Ledger Technologies

PSFNetwork may in the future implement tokenization, blockchain, distributed ledger, digital securities, digital wallet, or similar technologies for the purpose of recording and transferring ownership interests, tracking transactions, or administering investor accounts. If and when such functionality is implemented:

  • Certain transaction information, including ownership records, transfer history, and related data, may be recorded on distributed ledgers that are designed to be immutable and may be publicly visible or accessible. Information recorded on a distributed ledger cannot be deleted, corrected, or removed in response to a privacy request.

  • We will provide notice in advance of implementing any functionality that records personal information on a distributed ledger, and will describe in the applicable offering or platform documentation what information will be recorded and how it may be accessed.

  • Users who interact with blockchain-based features may be required to maintain digital wallets or use third-party wallet providers whose own privacy policies and terms will apply to information you submit to or through those providers.

Nothing in this section creates any commitment or obligation to implement any blockchain-based functionality. Any such implementation would be subject to additional disclosures and applicable regulatory requirements.

10.  Your Privacy Rights and Choices

Accessing and Correcting Your Information. You may review and update certain Personal Information in your account settings or by contacting us at support@psfnetwork.com. For information that cannot be updated through the platform, we will do our best to assist you in a reasonably timely manner.

Deleting Your Account. You may request deletion of your account and associated Personal Information by emailing support@psfnetwork.com. We will process your request consistent with our legal and regulatory obligations. Certain information — particularly investor verification, compliance, and transaction records — may be subject to mandatory retention requirements that limit or delay deletion.

Downloading Your Data. You may request a copy of your Personal Information, including in machine-readable format, by contacting us at support@psfnetwork.com.

Marketing Communications. You may opt out of marketing and promotional emails by following the unsubscribe instructions in those messages or by contacting us at support@psfnetwork.com. Even if you opt out of marketing, we will continue to send you communications required in connection with your investment account, such as tax forms, distribution notices, and material regulatory disclosures.

Unsolicited Messages. PSFNetwork prohibits the use of unsolicited messages, including email, SMS, social media messages, and automated calls, to advertise or promote our website, services, or investment offerings.

Withdrawing Consent. Where we process your information on the basis of consent, you may withdraw that consent at any time by contacting us at privacy@psfnetwork.com. Withdrawal of consent does not affect the lawfulness of any processing that occurred before withdrawal.

11.  U.S. State Privacy Rights

Depending on the state in which you reside, you may have specific privacy rights under applicable state law. This section describes the rights available to residents of states with comprehensive consumer privacy legislation. To exercise any of these rights, contact us at privacy@psfnetwork.com with your request and your state of residence. We will respond within the timeframe required by applicable law.

Please note that certain personal information processed in connection with investor verification, securities transactions, and AML/KYC compliance may be subject to exemptions under applicable state privacy laws, including exemptions for information regulated under the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and applicable federal and state securities laws. Where an exemption applies, we will identify it in our response to your request.

California (CCPA/CPRA). California residents have the right to know what personal information we collect, use, disclose, and sell; the right to delete personal information (subject to exceptions); the right to correct inaccurate personal information; the right to opt out of the sale or sharing of personal information (we do not sell personal information); the right to limit use and disclosure of sensitive personal information; and the right to non-discrimination for exercising these rights. California residents may also designate an authorized agent to make requests on their behalf. We do not sell or share personal information as those terms are defined under the CCPA/CPRA.

Virginia (VCDPA). Virginia residents have the right to access, correct, delete, and obtain a copy of personal data we hold about them; the right to opt out of the processing of personal data for purposes of targeted advertising, sale, or profiling in furtherance of decisions that produce legal or similarly significant effects; and the right to appeal a denial of a privacy request. We will respond to appeals within 60 days of receipt.

Colorado (CPA). Colorado residents have the right to access, correct, delete, and obtain a copy of personal data; the right to opt out of targeted advertising, sale of personal data, and profiling in furtherance of decisions with legal or similarly significant effects; and the right to appeal a denial of a privacy request within 45 days. We will respond to appeals within 45 days.

Connecticut (CTDPA). Connecticut residents have the right to access, correct, delete, and obtain a copy of personal data; the right to opt out of targeted advertising, sale of personal data, and profiling in furtherance of decisions with legal or similarly significant effects; and the right to appeal a denial of a privacy request. We will respond to appeals within 60 days.

Utah (UCPA). Utah residents have the right to access and obtain a copy of personal data we hold about them, the right to delete personal data they have provided to us, and the right to opt out of the sale of personal data and targeted advertising.

Texas (TDPSA). Texas residents have the right to access, correct, delete, and obtain a copy of personal data; the right to opt out of the processing of personal data for purposes of targeted advertising, sale, or profiling; and the right to appeal a denial of a privacy request. We will respond to appeals within 60 days.

Oregon (OCPA). Oregon residents have the right to access, correct, delete, and obtain a copy of personal data; the right to a list of specific third parties to whom personal data has been disclosed; and the right to opt out of targeted advertising, sale of personal data, and profiling.

Montana (MCDPA). Montana residents have the right to access, correct, delete, and obtain a copy of personal data; the right to opt out of targeted advertising, sale of personal data, and profiling in furtherance of decisions with legal or similarly significant effects; and the right to appeal a denial of a privacy request.

Delaware (DPDPA). Delaware residents have the right to access, correct, delete, and obtain a copy of personal data; the right to opt out of targeted advertising, sale of personal data, and profiling; and the right to appeal a denial of a privacy request within 60 days.

We will not discriminate against you for exercising any of the rights described in this section. To the extent we deny a rights request, we will explain the basis for the denial and, where applicable, describe how you may appeal. We will verify your identity before processing any request to access, correct, or delete personal information. We are not required by law to honor requests that we cannot verify.

12.  Data Retention

We retain Personal Information for as long as your account is active, as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. The following principles govern our retention practices:

  • Account information is retained for the duration of your account and for a reasonable period thereafter to allow for dispute resolution and legal compliance.

  • Investment and transaction records are retained for the periods required by applicable securities laws and regulations, including requirements imposed by the SEC and FINRA, which may be seven years or longer.

  • AML/KYC and identity verification records are retained for the periods required by applicable anti-money laundering laws and the policies of our registered broker-dealer partners.

  • Analytics and usage data is retained in identifiable form only as long as necessary for the purpose for which it was collected, and in anonymized or aggregated form for longer periods.

When information is no longer required to be retained, we delete or anonymize it in accordance with our data disposal procedures.

13.  Users Located Outside the United States

PSFNetwork is headquartered in the United States. The Services are controlled and operated from the United States. Securities offerings made available through the Services are offered only in jurisdictions where such offerings may lawfully be made under applicable federal, state, and foreign securities laws. Investors located outside the United States may be subject to additional eligibility requirements, investor verification procedures, and jurisdictional restrictions as determined by applicable law and by our registered broker-dealer partners. PSFNetwork reserves the right to restrict access to any offering in any jurisdiction at any time and without notice.

Personal Information you submit to us may be stored, transferred, and processed in the United States or in any country where we maintain facilities or engage service providers. By accessing or using the Services, you acknowledge and consent to the transfer of your Personal Information to the United States and to other jurisdictions that may have data protection laws different from those of your country of residence.

In certain circumstances, courts, law enforcement agencies, regulatory authorities, securities regulators, or national security authorities in the United States or other jurisdictions may be entitled to access your Personal Information pursuant to applicable law.

If you access the Services from outside the United States, you do so at your own initiative and are responsible for compliance with any local laws applicable to your use of the Services, including any laws governing the purchase of securities, the transfer of funds internationally, and the use of online platforms. PSFNetwork makes no representation that the Services comply with the laws of any jurisdiction outside the United States.

14.  Children's Privacy

The Services are not directed to, and we do not knowingly collect Personal Information from, children under the age of 18. If we learn that we have inadvertently collected information from a child under 18, we will delete it promptly. If you believe a child has provided us with personal information without parental consent, please contact us at support@psfnetwork.com.

15.  Third-Party Links and Services

The Services may contain links to third-party websites, platforms, or services that operate under their own privacy policies. We have no control over those parties and are not responsible for their data practices. We encourage you to review the privacy policies of any third-party sites you visit. Our linking to or mentioning a third-party service does not constitute an endorsement or representation about that party's privacy practices.

16.  How to Contact Us

If you have questions, concerns, or requests relating to this Policy or the handling of your Personal Information, please reach out through any of the following:

General inquiries:  support@psfnetwork.com

Privacy and data rights:  privacy@psfnetwork.com

Legal notices:  legal@psfnetwork.com

PSFNetwork Inc.

62 South 3rd Street

Williamsburg, Brooklyn, NY 11249

Registered Agent: c/o Corporation Service Company, 251 Little Falls Drive, Wilmington, Delaware 19808

Important information

© 2026 PSFnetwork. All rights reserved.