Effective [Month DD, YYYY]
Last updated [Month DD, YYYY]
Aventerra [Legal Entity Name] (“Aventerra,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us. This policy explains how we collect, use, disclose, and safeguard information when you visit aventerra.com and any related services that link to this policy (the “Site”), including our secure investor portal.
By accessing or using the Site, you acknowledge that you have read and understood this policy. If you do not agree, please do not use the Site.
01. Who we are
Aventerra is a real estate investment and advisory firm. This Site is operated by [Legal Entity Name], located at [Street Address, City, State ZIP]. For privacy questions, contact us at privacy@aventerra.com or using the details in Section 14.
02. Information we collect
We collect information in three ways: information you provide directly, information collected automatically as you use the Site, and information we receive from third parties.
Information you provide
- Contact and inquiry information — name, email, phone, company, and the contents of any message when you complete a form or reach out to us.
- Investor portal information — if you register for or access our secure portal, we may collect your name, contact details, login credentials, entity affiliation, accreditation or eligibility information, tax identification, banking or distribution details, and documents you exchange with us.
- Career and other submissions — information contained in resumes, applications, or other materials you submit.
Information collected automatically
- Device and connection data — IP address, browser type, operating system, device identifiers, and referring URLs.
- Usage data — pages viewed, links clicked, time spent, and other interaction data.
- Cookies and similar technologies — see Section 6 and our Cookie Policy.
Information from third parties
We may receive information from business partners, service providers, identity- or accreditation-verification vendors, analytics providers, and publicly available sources, which we may combine with information we already hold.
03. How we use your information
We use personal information to respond to inquiries and provide requested materials; operate, secure, and authenticate the investor portal; administer investor relationships, including reporting and distributions; verify investor eligibility, accreditation, and identity; operate, improve, and analyze the Site; send administrative and, where permitted, marketing communications you can opt out of; detect and prevent fraud and misuse; and comply with applicable laws and enforce our agreements.
04. Legal bases for processing (EEA / UK)
If you are located in the European Economic Area or the United Kingdom, we process personal data on one or more of the following legal bases: your consent; performance of a contract with you; compliance with a legal obligation; and our legitimate interests in operating and securing the Site and managing our business, where not overridden by your rights.
05. How we share information
We do not sell your personal information for money. We may share information with:
- Service providers performing functions on our behalf (hosting, analytics, communications, identity verification, IT security), bound by confidentiality obligations;
- Affiliates within the Aventerra group;
- Fund administrators, custodians, banks, auditors, and transfer agents in connection with investor administration;
- Professional advisors such as lawyers, accountants, and insurers;
- Authorities and other parties where required by law or to protect rights, safety, and property; and
- Successors in connection with a merger, financing, acquisition, or sale of assets.
Some sharing for cross-context behavioral advertising or analytics may be considered a “sale” or “sharing” under certain U.S. state laws; see Section 9 for your choices.
06. Cookies and tracking technologies
We use cookies, pixels, and similar technologies to operate the Site, remember preferences, measure performance, and — where applicable — support marketing. You can manage your preferences through our cookie banner and Cookie Policy, which describes the categories of cookies we use and how to control them.
07. Data retention
We retain personal information for as long as needed to fulfill the purposes described in this policy, to maintain investor and business records, and to comply with legal, tax, accounting, and regulatory requirements. When information is no longer required, we take reasonable steps to delete or anonymize it.
08. Data security
We maintain administrative, technical, and physical safeguards designed to protect personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your portal credentials confidential and for notifying us of any suspected unauthorized access.
09. Your privacy rights
Depending on where you live, you may have rights to access, correct, delete, or port your information; to opt out of certain processing, including targeted advertising, “sale,” or “sharing”; to withdraw consent; and to appeal a decision about your request. To exercise these rights, contact us using the details in Section 14. We will verify your request and respond within the timeframe required by law, and we will not discriminate against you for exercising your rights.
California residents (CCPA / CPRA)
California residents have the rights to know, access, correct, delete, and opt out of the “sale” or “sharing” of personal information, and to limit the use of sensitive personal information. We do not sell personal information for monetary consideration.
Other U.S. states
Residents of states with comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, and Texas) may have similar rights, which we honor as required by the law of your state.
EEA / UK residents
You have rights under the GDPR and UK GDPR, including those above and the right to lodge a complaint with your local supervisory authority.
10. International data transfers
We are based in the United States, and information we collect may be processed in the United States and other countries whose data-protection laws may differ from those in your jurisdiction. Where required, we implement appropriate safeguards, such as Standard Contractual Clauses, for such transfers.
11. Children’s privacy
The Site is intended for a professional and investor audience and is not directed to children. We do not knowingly collect personal information from individuals under [16/18]. If you believe a child has provided us information, please contact us and we will take appropriate steps to delete it.
12. Third-party links
The Site may contain links to third-party websites and services we do not control. This policy does not apply to those sites, and we encourage you to review their privacy practices.
13. Changes to this policy
We may update this policy from time to time. When we do, we will revise the “Last updated” date above and, where appropriate, provide additional notice. Your continued use of the Site after changes take effect constitutes acceptance of the revised policy.
14. Contact us
If you have questions about this policy or wish to exercise your rights, contact us at:
[Legal Entity Name]
Attn: Privacy
[Street Address]
[City, State ZIP]
Email: privacy@aventerra.com
Phone: [+1 (000) 000-0000]
