Privacy Policy

In this Website Privacy Policy, REAL Homeownership Trust, LLC or “REAL” or “we”, provide information about how we use, collect, and transfer personally identifiable data from website visitors to SeashineCapital.com, and other websites that we operate and for which we provide a link to this Privacy Policy (collectively the “Website”).

Scope

This Privacy Policy covers only data collected through the Website and any other data collection or processing, including, affiliated websites that display a direct link to this Privacy Policy.

Collection, Use, and Sharing of Data

Seashine collects information from visitors of the Website, including the domain names, IP and MAC addresses, browser types, and unique device identifiers of such visitors. This information includes the number of visits, average time spent on the Website, pages viewed, and similar information. This information may also include usage information about the page-by-page paths you take as you browse through the Website. Seashine uses this information to measure the use of the Website and to develop ideas to improve the content of the Website. For more information regarding our use of this information, please see the sections on “Cookies and Other Tracking Technologies” and “Analytics” below.

There are times, however, when we may need additional information from you, including personal information that may be used to identify you. This information includes items such as your name, address, phone number, and email address. The information we collect is typically used by us to respond to your inquiry, process a transaction, or allow you to access specific account/profile information. We may also use your personal information to: improve the Website or Seashine products and services; customize your experience with the Website, or to serve you specific content that is relevant to you; contact you regarding your use of the Website and, in our discretion, changes to our policies; provide you with website-related notices; send you advertisements for Seashine products and services; and for purposes disclosed elsewhere in this Privacy Policy, at the time you provide your personal information, or with your consent. If you choose to share any personal information with us, we will use it in accordance with this Privacy Policy.

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on website forms and in other communications.

• Information about your transactions with us, our affiliated companies, or others.

• Information we receive from third parties (if we receive personal information from a third-party source and/or if we combine the information we receive from these third-party sources with your personal information, we will treat that information as personal information. We are not responsible for the accuracy of the information provided by third parties or how such third parties collect, use, and share such information).

Prospective applicants for the REAL Program will be asked to provide personal information including name, current address, phone number(s), email address, social security number (SSN) or individual tax identification number (ITIN), financial data, employment data, date of birth, residence history, military status, and other information necessary to process your application and to evaluate program eligibility. Furthermore, prospective applicants will be asked to provide the names and dates of birth for all prospective occupants including children.

We may share personal information with non-affiliated third parties as necessary for us to provide the product or services requested, as permitted by law, with third-party service providers so that they may perform certain services for us, or as otherwise specified herein. Such disclosures may include situations in which we are required to respond to subpoenas or other legal processes, or are responding to the request of governmental authorities conducting an investigation.

We may store your information indefinitely, including the period after which any Customer relationship has ceased. Such information may be used for any internal purpose, such as quality control efforts or customer analysis.

We may, in our sole discretion, share with third parties, information that is not associated with your name or identity, such as website usage information, non-personally identifiable demographic information, and aggregate user statistics.

We may also provide all of the types of nonpublic personal information listed above to one or more of our affiliated companies.  Affiliated companies include but are not limited to Seashine Financial, LLC, Seashine Owner Co, LLC, and Seashine Asset Management, Inc.  From time-to-time, Seashine may become affiliated with other companies or trusts associated with the REAL Program.

It is possible that Seashine, its subsidiaries, affiliates, joint venture companies, or any combination of them, could merge with or be acquired by another legal entity. In such event, or in the event of any other proposed or actual purchase, sale (including a liquidation, realization, foreclosure, or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance, or financing of all or any portion of Seashine or of any of the business or assets or shares of Seashine or a subsidiary or division thereof, Seashine may share your information with third parties. You will have the opportunity to opt out of any such transfer if, in our discretion, the new entity plans to handle your information in a way that differs materially from this Privacy Policy.  Furthermore, we may also provide all the information we collect, as described above, to companies that perform marketing services on our behalf, on behalf of our affiliated companies or to other financial institutions with which we or our affiliated companies have joint marketing agreements. In some circumstances, we will request your consent to share your information with non-affiliated third parties, such as lenders, realtors, and insurers, so that they may offer you products and services that may be of interest to you.