Updated: October 27 2023

Thank you for visiting First Coast Real Estate Partners I, LP (“First Coast Real Estate Partners” or “FCREP” or “we” or “us”).  This Privacy Policy describes the personal data handling policies of FCREP, including the following:

1. What personal data we collect, including from our online applications, including the investor portal (the “Portal”), our services and our website at fire-management.com (the foregoing, collectively, the “Services”);
2. How we use the data;
3. With whom we may share the personal data;
4. Legal basis for processing the data;
5. Storage and security of your data;
6. Your privacy rights, choices and disclosures, including those for Europe and California;
7. Users outside the United States;
8. Links to other sites;
9. Privacy Policy updates; and
10. Contact Information.

1.    Personal Data We Collect or Process

• The Services capture some information about you automatically utilizing background local storage and session storage technologies (“Cookies”). Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of the Services. Examples of information of this type are your IP address, the browser you are using, the operating system you are using, the pages on the website that you visit and details of your activity.  When we use Cookies, we may use “session” Cookies that last until you close your browser or “persistent” Cookies that last until you or your browser delete them. You may change your browser setting to decline the use of Cookies.

We use Google Analytics, which uses Cookies to identify the frequency of use of certain areas of our website and to identify preferences. For more information regarding how Google collects, uses and shares your information please visit http://www.google.com/policies/privacy/partners/. Google will use this information to analyze your use of the Services, compile reports on activity for us, and perform further services associated with website use and Internet use. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here:  https://tools.google.com/dlpage/gaoptout?hl=en.

We may operate social media pages on third party networks and have social media icons on our website. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers.  Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.

• We also collect information that you provide to us voluntarily. We collect the information that you provide to us when you sign up to receive newsletters, advisories, announcements and invitations and when you contact us by email or phone.

In connection with provision of the Services through our applications, we request the following information, many elements of which are necessary for us to comply with our own Know Your Customer and Anti-Money Laundering requirements:

• Contact Data, including billing address, residential address, email address and telephone numbers. If you provide your mobile number, you consent to receive communications from us via SMS text messaging for multi-factor authentication for access to the Portal.
• Information about your identity, including first name, maiden name, last name, title, username or similar identifier, tax ID, marital status, date of birth, country of birth, gender, employer details, identity document number, nationality and any other information contained in any identification documents you provide to us (e.g., your passport or driver’s license).
• Financial data, including bank account details.
• Information about your trading behavior.
• Your preferences with respect to multi-factor authentication.

We utilize Juniper Square to collect information on our behalf. When you register on the Portal, you may be re-directed to the Juniper Square website for completion of investor onboarding documents and the uploading of documents described above.

When you register for an account on the Portal or otherwise use our Services, we may receive information about your criminal convictions when we perform certain verification or compliance checks. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal obligations.

From time to time our interactions with you will be conducted over the telephone or video-conference, and such telephone calls and video conferences may be recorded.

We do not knowingly collect information from users of our website under the age of 18 and/or their internet usage, and such persons are not authorized to use the Services. If we obtain actual knowledge that a user is under 18, we will take steps to remove that user’s personal information from our databases. By using the Services, you represent that you are at least 18 years old and of legal age to enter into legal agreements.

2.    How We Use the Data

We use data about you for the following purposes, as permitted by applicable law:

• To on-board you as a client, verify your identity, and to satisfy know your customer and anti-money laundering obligations.
• For general business purposes, including managing your account and relationship with us, responding to enquiries and requests, and administrative purposes.
• To facilitate registrations and transactions.
• To complete services requested by you.
• To manage and assure the integrity of our platform.
• Provide the publications and information you request.
• To communicate with you, including to provide status updates, transactional emails and other service communications, to provide you with notices about your account and to contact you through telephone, text, email or chat, as permitted by law.
• To communicate with you for research purposes, including to request your participation in surveys.
• To provide, maintain, and protect our Services.
• To monitor the performance of our Services and improve your user experience.
• To satisfy legal obligations and compliance requirements under laws and regulations applicable to us and our affiliates (e.g., know your client and to check and verify your identity).
• To carry out anti money laundering checks, protect against the risk of fraud, risk screening and to detect and prevent money laundering or other financial crime.
• To protect and defend the rights and property of our users, FCREP and its affiliates, and third parties.
• To comply with legal obligations and regulations to which FCREP and its affiliates are subject and cooperate with regulators, other appropriate agencies or authorities and law enforcement bodies, both within your jurisdiction and internationally.
• To develop, improve and test certain of our products and services.
• For other purposes that we tell you about when you register or provide data about yourself to us.
• For other legitimate business and lawful purposes.

3.    With Whom We Share Personal Data

We may share your personal data to third parties (within or outside your country of residence) who perform services on our behalf, including without limitation Juniper Square (described in Section 1), fund administrators, our verification services providers, who help us detect and prevent fraud and comply with our legal obligations, technology providers and developers, and professional advisors.

FCREP may disclose any information we have about you (including your identity) if we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Services, or to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, or the rights or property of visitors to or users of the Services. Client reserves the right at all times to disclose any information that we deem necessary to comply with any applicable law, regulation, legal process or governmental request. FCREP also may disclose your information when we determine that applicable law requires or permits such disclosure, including exchanging information with other companies and organizations for fraud protection purposes.

We may share your data with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party.

We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes.

We may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

4.    Grounds for Using Your Personal Data

We rely on the following legal grounds to process your personal information:

Consent. Some uses of your personal data as described in this Privacy Policy are subject to your consent.  To withdraw your consent, please contact us at invest@fcrepmanagement.com.  You may also refrain from providing, or withdraw, your consent for Cookies via your browser and mobile settings.

Performance of a contract. We may need to collect and use your personal information to enter into a contract with you and to perform Services that you request.

Legitimate Interests. We may use your personal information for our legitimate interests to provide our Services and to improve our Services and the content contained thereon.  We may use technical information as described in this Privacy Policy and use personal information for purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.

5.    Storage and Protection of Your Personal Data

We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store email addresses until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.

We take reasonable administrative, physical and technical precautions to protect your personal data and communications between us.  This includes, when required or as we deem appropriate and feasible under the circumstances, encryption and written commitments from third parties that may have access to your data that they will protect the data with reasonable safeguards.

No Internet or e-mail transmission is ever fully secure or error free, however.  We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control.  Users assume the risk of security breaches and the consequences resulting from them.  Please be careful in deciding what information you send to us via email or over the Internet.

6.    Your Rights, Choices and Disclosures

(a)   General.

This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations.  If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at invest@fcrepmanagement.com or make changes to any user profile information connected to your account. Section (b) below describes the rights of those individuals located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union’s General Data Protection Regulation (GDPR). Section (c) describes the rights of residents of California (or another jurisdiction that has adopted laws substantially similar to the California Consumer Privacy Act).

Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority and the right to appeal our decision regarding a data access request.

• Your European Privacy Rights and Choices.

If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union’s General Data Protection Regulation (GDPR), your privacy rights include the following:

• Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
• Right of access, correction, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations. To make a request or to ask us a question about our data practices, please contact us via email at invest@fcrepmanagement.com.
• Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
• Right to object at any time. You have the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.
• Right to data portability. You have the right to data portability of your own personal data by contacting us.
• Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.
• Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
• California Disclosures

California Consumer Privacy Act Disclosures. If you are a resident of California (or another state that has adopted laws substantially similar to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”)), you have the right to request:

• The categories of personal information, including sensitive personal information, we have collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose of collecting, selling or sharing personal information;
• The categories of third parties with whom we share or sell personal information;
• The categories of personal information about you that we have disclosed for business purposes; and
• The specific pieces of personal information we have collected about you.

Additionally, you have the right:

• to know the length of time we retain your personal information;
• to request deletion of your personal information;
• to request the correction of any inaccurate data;
• to opt out of the sale or sharing of your information (if applicable);
• to limit the use of sensitive personal information (if applicable); and
• to not be discriminated against for exercising any of your CCPA/CPRA rights.

Please see the chart below regarding the categories of data we may have collected or received in the 12 months preceding the effective date of this Privacy Policy from consumers in connection with providing our Services and to whom we may have disclosed the information for business purposes.

Any sensitive data we collect is used only for a business purpose and not for the purposes of inferring characteristics of a consumer.

We do not sell or share personal information for monetary consideration under CCPA. Personal data may be provided to our service providers, contractors and, pursuant to Sections 1798.140(ad)(2)(A) and 1798.140(ah)(2)(A) of the CCPA/CPRA, to third parties.

To submit a data access request, please email us at invest@fcrepmanagement.com.  

You may also submit a request on our website form located at https://fcrepmanagement.com/contact/. If you submit a data subject request, we will ask for your name, email address and phone number, and we will endeavor to authenticate your account. We may also require that you submit your request via the Services’ standard authentication procedures (i.e., log on with username and password to submit a request) and/or provide information about any historical transactions with the Services to ensure you are the person you say you are. If this information or these processes are insufficient to verify your identity and assess your privacy request, we may need to ask for additional information.  You may also designate an authorized agent to make a CCPA privacy request.

California “Shine the Light” Information-Sharing Disclosure: FCREP does not disclose any information about you to third parties for direct marketing purposes.

California Do Not Track Disclosure: We do not track our customers over time and across third party websites to provide targeted advertising.

7.    Users Outside the United States

FCREP and the Services are controlled and operated from the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities.  Personal data may also be transferred from the country of your residence to other countries, including the United States.  By visiting or using our Services, you are consenting to the transfer of your information from your jurisdiction to the United States.

8.    Links to Other Sites

Our Services may contain links to other websites for your convenience or information.  These websites may be operated by companies unaffiliated with us, and we are not responsible for the content or privacy practices of those websites.  Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.

9.    Privacy Policy Changes

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the Services after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy.  Please review this Privacy Policy periodically and especially before you provide personal data to us.  We will post a notice on our website to notify you of any material changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated. We will also communicate changes as required by applicable law.

10.    Questions and Contact Information

FCREP is located at:

First Coast Real Estate Partners I, LP

1819 Goodwin St.

Jacksonville, FL 32204

Please contact us if you have any questions about our Privacy Policy. You may contact us by sending correspondence to the foregoing address or by emailing us at invest@fcrepmanagement.com.