Privacy Policy
This Privacy Policy was last updated on November 19, 2025.
This Privacy Policy sets out the privacy practices of the website located at www.aracapital.com (the “Website”), as owned and operated by American Realty Advisors (“ARA”, “we,” “our,” “us”). For purposes of clarity, the Website does not include the Client Portal hosted by Intralinks or any other websites not hosted on www.aracapital.com. For purposes of this Privacy Policy, unless otherwise stated, “information” or “personal information” means information relating to an identified or identifiable individual. This Privacy Policy does not apply to any information that we may collect offline, through another website (including the Client Portal), or through any other means (for example, at a live event or through the mail, which, for natural persons, is subject to ARA’s privacy policy adopted under the Securities and Exchange Commission’s Regulation S-P). Any terms that are not defined in this Privacy Policy shall have the meaning ascribed to them in our Terms of Use.
By using or attempting to use the Website, you accept, without limitation or qualification, and are agreeing to be bound by and comply with everything contained in our Terms of Use, including this Privacy Policy. If you do not agree to any of these provisions, do not use or attempt to use the Website.
If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below.
If you are a resident of the U.S., see our U.S. State-Specific Disclosures.
Information Collection
A. Information You Provide
We collect information that you provide directly via the Website, such as when you access our content or complete the “Contact Us” form on the Website. We may use Service Providers (defined below) to collect this information.
The information we collect includes information that identifies you personally (whether alone or in combination). The categories of information we collect and have collected include:
- Contact Identifiers, such as your name, phone number, and e-mail address. We may also collect business contact identifiers, such as the company you represent and job title.
- Characteristics and Demographics, including your country of residence.
- Account Credentials, such as your username and password.
- Job Applicant Data, including your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.
- Content. We collect the content of messages you send to us, such as your feedback or questions and information you provide to us.
Please do not provide any information that we do not request.
B. Information We Collect from Your Browser or Device
When you visit the Website, we and our Service Providers may collect and store certain technical information from your browser and device automatically. The categories of information we automatically collect and have collected include:
- Device Identifiers, including your device’s IP address and MAC address.
- Internet Activity. We collect data about the features you use, the pages you visit, the e-mails you view, the time of day you browse, your referring and exiting pages, and other similar information.
- Device Information. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information.
- Non-precise Location Data. We collect non-precise location data (e.g., location derived from an IP address or data that indicates a city or postal code level).
We use various technologies to collect this information (“Tracking Technologies”), including the following:
- Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate a website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
- Pixels. A pixel (also known as a web beacon) is code embedded in a service that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a service that contains a pixel, the pixel may permit us or another party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device.
For further information on Tracking Technologies and your rights and choices regarding them, see the “Your Privacy Choices” section.
C. Information from Other Sources
We also collect information from other sources. The categories of other sources from which we collect information include:
- Business partners that offer co-branded services, sell or distribute our products, or engage in joint marketing or promotional activities.
- Third-party vendors and related parties we work with in connection with receiving analytics, advertising, security, and fraud prevention services.
- Social media platforms with which you interact. For example, when you engage with our content on social media (such as through our brand page or direct messages), we may collect information such as your contact identifiers and any comments you provide. We may also receive additional information from the social media platform that you have authorized the platform to disclose to us. If you publicly reference our Service on social media (such as by tagging us or using a hashtag associated with us in a post), we may use your reference on or in connection with our Service.
- Data providers, such as licensors of private and public databases.
- Public sources, such as information in the public domain.
D. Information We Infer
We infer information from other information we collect, including to generate information about your likely preferences or other characteristics.
E. Sensitive Information
Some of the information we collect may be considered sensitive under applicable law. See additional disclosures in your region for details.
Use of Information We Collect
We use information for our business purposes in accordance with the practices described in this Privacy Policy. Our business purpose for collecting and using information includes the following:
- Operate and manage our Website.
- Perform services requested by you, such as to respond to your comments, questions, and requests.
- Prevent and address fraud, breach of policies or terms, and threats or harm.
- Monitor and analyze trends, usage, and activities.
- Conduct research, including focus groups and surveys.
- Improve the Website or other services we provide including, apps, marketing efforts, products and services.
- Develop and send you direct marketing where permitted in accordance with applicable laws.
- Fulfill any other business or commercial purposes disclosed to you and with your consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the “Your Rights and Choices” section below.
Disclosure of Information
We disclose information we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have disclosed information include:
- Service Providers. We may disclose your information to service providers that collect and process information on our behalf (“Service Providers”). Service Providers assist us with services such as data analytics, marketing, website hosting, and technical support. To the extent required by law, Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
- Affiliates. We may disclose your information to our related entities. For example, we may disclose your information to our affiliates for customer support, marketing, and technical operations.
- Merger or Acquisition. We may disclose your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our business to another business.
- Security and Compelled Disclosure. We may disclose your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your information to protect the rights, property, life, health, security and safety of us, the Website or any other party.
- Consent. We may disclose your information for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may disclose aggregated information which does not identify you or de-identified information about you with other parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we disclose your information, please see the “Your Privacy Choices” section below.
Your Privacy Choices
A. Jurisdictional Rights
See additional disclosures regarding your rights to exercise choice if you live in the following regions:
B. Tracking Technology Choices
- Cookies and Pixels. You may be able to manage cookies through your browser settings. When you manage cookies, pixels associated with such cookies may also be impacted. Please note that cookie management only applies to our website. If you use multiple browsers, you will need to instruct each browser separately. If you delete or reset your cookies, you will need to reconfigure your settings. Your ability to limit cookies is subject to your browser settings and limitations.
- Preference signals. Your browser or extension may allow you to automatically transmit Do Not Track and other preference signals. Except as required by law, we do not respond to preference signals.
- Analytics Management. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout. Please note that this applies only to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt-outs offered by other entities.
Please be aware that if you disable or remove Tracking Technologies, some parts of the Website may not function correctly.
C. E-mails
You can unsubscribe from receiving promotional emails by following the unsubscribe instructions at the bottom of the email, or emailing us at info@aracapital.com with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional messages.
Data Security
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
Links to Other Sites
Our Website may contain links to third-party websites (including the Client Portal website and any social media websites) and if you click on (i.e., select) such a link, your browser will leave our Website. Our Terms of Use do not apply to and we do not control or endorse any such third-party website. ARA does not monitor any third-party websites linked from or to the Website and makes no representation or warranty, express or implied, for the Content or the security of any such linked website. ARA is not responsible for the information, materials or services obtained on or from such third-party website and will not be liable in any respect for any damages arising from your access of such website. Any such links are provided for the convenience of the users of the Website. The inclusion of such links does not imply any adoption, endorsement, representation or warranty by ARA with respect to any such website or the Content or services contained through such website. You should review the terms and conditions and privacy policies that apply to these third-party websites so you will know the terms that apply to you when you visit their websites.
Children
The Service is not directed toward children under 16 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at info@aracapital.com. We will delete the personal information in accordance with COPPA.
International Transfer
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Website from outside of the U.S., please be aware that information collected through the Website may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Website or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy.
Retention
We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
U.S. State-Specific Disclosures
Disclosures for California Residents
California provides additional rights to California residents, including through the California Consumer Privacy Act as replaced by the California Privacy Rights Act (“CCPA”). This section addresses those rights and only applies to California residents.
A. Notice of Collection
For residents of California, at or before the time of collection of your personal information, you have the right to receive notice of our data practices. Our data practices are as follows:
- Collection. The categories of personal information we have collected in the past 12 months and the categories of sources from which the personal information is collected are set out in the Information Collection section above.
- Purpose. The specific business and commercial purposes for collecting and using personal information are set out in the Use of Information We Collect section above.
- Disclosure. The categories of persons to whom personal information is disclosed, including service providers for business purposes, are set out in the Disclosure of Information section above. We disclose the categories of personal information listed in the Information Collection section above to service providers for business purposes.
- Sales and Shares. We do not “sell” or “share” your personal information as those terms are defined by the CCPA. We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.
- Retention. We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
B. Requests
You have the right to exercise choice over your personal information as follows:
- Verifiable Requests: You have the right to:
- Know what personal information we have collected about you, specifically have the right to know the categories of sources from which personal information was collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of personal information that we sold, shared, or disclosed for a business purpose, the categories of third parties to whom we disclosed personal information, and the specific pieces of personal information we have collected about you;
- Correct inaccurate personal information we maintain about you; and
- Delete personal information that we have collected from you.
These rights are verifiable rights, meaning that we need to verify your identity before fulfilling them. To exercise any of these rights, please email us at info@aracapital.com.
If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
- Shine the Light. Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
Your rights are subject to exceptions and our retention practices. To the extent permitted by law, rights requests must be exercised through the applicable designated method listed above.
C. Authorized Agent
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.
D. Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
Disclosures for Residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Tennessee, Texas, Utah, and Virginia.
Data Practices
For residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, our practices regarding the collection, use, disclosure, and retention of your personal data are set out in the main Privacy Policy above.
We do not sell your personal data as that term is defined under applicable law or process your personal data for purposes of targeted advertising. We do not process personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.
Requests
You have the right to exercise choice over your personal data as follows:
- Verifiable Requests: You have the right to:
- Confirm whether or not we are processing your personal data, and in some regions, confirm the categories of personal data we have processed;
- Access your personal data;
- Correct inaccuracies in your personal data;
- Delete your personal data;
- Obtain a copy of your personal data that you previously provided to us in a portable and readily usable format.
If you are a Minnesota or Oregon resident, you also have the right to obtain a list of the specific third parties to which we have disclosed personal data.
If you are a Delaware or Maryland resident, you also have the right to obtain a list of categories of third parties to which we have disclosed your personal data.
If you are a Connecticut resident, you also have the right to obtain a list of the specific third parties to which we have sold personal information.
These rights are verifiable rights, meaning that we need to verify your identity before fulfilling them. To exercise any of these rights, please email us at info@aracapital.com.
If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
- Consent: You have the right to revoke consent previously given to us for the processing of your personal data. To revoke consent, write us at the email or postal address set out in the Contact Us section above (specifying the consent you wish to withdraw). If you withdraw consent, you may not be able to receive certain services related to that consent.
Your rights are subject to exceptions and our retention practices. You have the right not to be discriminated against for exercising any of your rights. To the extent permitted by law, rights requests must be exercised through the applicable designated method listed above. You may make a rights request using an authorized agent. Except for rights requests made by opt-out preference signal, we will require written and signed proof of the agent’s permission to do so and we may verify your identity directly with you.
You have the right to appeal our decision in response to your request. To appeal, please write us at the email or postal address set out in the Contact Us section above and specify what you wish to appeal. We will review and respond to your appeal in accordance with applicable law. If we deny your appeal, you may submit a complaint to your Attorney General as follows: Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia.
Additional Disclosures for Residents of Nevada
Nevada residents have the right to opt-out of sale of their information. To make a request, please write us at the email or postal address set out in the Contact Us section above and specify that you are making a “Nevada Opt-Out of Sale Request.” Your rights are subject to exceptions and our retention practices.
Changes to Our Privacy Policy
You understand that we have the right to change this Privacy Policy from time to time, subject always to applicable law and regulation. If we make changes, we will post the revised Privacy Policy on the Website and update the “Last Updated” date to reflect the date of the changes. We will notify you of any material changes to this Privacy Policy by prominently posting it on the Privacy Page of the Website.
Contact Us
If you have any questions about this Privacy Policy, please contact us by e-mail at info@aracapital.com or by telephone at (213) 233-5700 or using the “Contact Us” form on the Website.