Privacy Policy

What we collect depends entirely on why you are dealing with us. A visitor who reads the site and leaves is in the first category alone. An investor who subscribes to a partnership is in most of them.

Contact information and identifiers. Your name, email address, phone number, mailing address, employer and job title, and the role you selected when you contacted us — investor, tenant, broker, capital partner, landowner, contractor, or career inquiry. If we later provide an investor portal, we would also hold the username and credentials for it.

Accreditation information. Where the company makes a private offering, an investor confirms their financial eligibility to us on a written questionnaire before subscribing — income and net-worth ranges, the qualifying test relied on, and any professional credential relied on instead. We do not require you to send the underlying tax returns, account statements, or credit reports, and you should not send them to us unprompted.

If we ever ask for documents behind a questionnaire — because a particular offering or a lender requires it — we will say so, tell you where to send them, and tell you what happens to them afterwards. Section 10 covers how to send anything sensitive.

Investor and subscription information. The legal name of the subscribing person or entity, your taxpayer identification number, bank and wiring instructions, formation or trust documents and the identity of beneficial owners where you subscribe through an entity, your signature, and the record of your capital account with the partnership — what you paid in, what was paid out to you, how profit and loss were allocated, and the annual tax schedule issued to you.

Counterparty information. For tenants, brokers, landowners, lenders, contractors, and vendors: company and contact details, the requirement or the site under discussion, brokerage licence and commission terms, ownership and title records, insurance certificates, tax forms such as a W-9, references, and the correspondence and documents exchanged during a transaction.

Career inquiry information. If you approach us about work, whatever you send — a résumé, work history, education, portfolio, and any other information you choose to include.

Device and website activity information. Your IP address, browser and operating system, device type, the page that referred you, the pages you viewed and when, and similar technical information recorded by our hosting provider in the ordinary course of serving the site. We derive only general location — the city or region an IP address resolves to. We do not collect precise location.

Communications. What you send us through the contact panel, by email, or by phone, and our record of it — including what was discussed, what was sent to you, and when.

Information about other people that you give us. A co-investor, a spouse, an adviser, a reference, or a colleague you ask us to include. If you give us someone else’s information, you should have their permission to do so.

Some of this is treated as sensitive information under one statute or another: your taxpayer identification or Social Security number, a government identification number, and financial account numbers. We collect it only where a subscription, tax reporting, or an anti-money-laundering obligation requires it, and we use it only for those purposes.

We do not draw inferences about you for marketing purposes, and we do not build advertising profiles.

To respond to you. To answer an inquiry, arrange a call or a site visit, and continue a conversation you started.

To confirm investor eligibility. To review the questionnaire you complete, to reach a conclusion on your eligibility, and to keep the record of it. That eligibility is a condition of the exemption these securities are offered under, not a preference of ours.

To administer an offering and the partnership that follows it. To prepare and process the documents you sign, arrange closing and the movement of funds, call capital when it falls due, pay out cash when there is any, maintain the register of members and their capital accounts, produce investor reporting, obtain member consents, and deliver your annual tax schedule.

To meet legal, tax, and regulatory obligations. To make the filings a private offering requires, including a Form D and any state notice filings; to meet tax reporting and withholding obligations; to respond to a regulator, a taxing authority, a court, or lawful process; and to satisfy the books-and-records rights that a partnership’s operating agreement and applicable state law give its members.

To screen for fraud, sanctions, and money laundering. To check the identity of anyone investing and the source of their funds, and to screen against applicable sanctions and watch lists. [COUNSEL] — confirm what screening is performed, by whom, and against which lists, before this sentence is published.

To evaluate a counterparty. To assess a tenant, a broker, a landowner, a contractor, or a vendor, and to negotiate, document, and perform an agreement with them — including creditworthiness and references where that is relevant to the transaction and permitted by law.

To operate, secure, and improve this website. To serve the site, diagnose faults, understand which pages are read and which are not, and detect and investigate activity that appears fraudulent or abusive.

To communicate with you about what you asked for. To send investor updates, notices about a partnership you hold an interest in, and — where we have a relationship with you and you have asked to hear about them — occasional emails about a new offering. Section 05 explains how to stop the last of these.

There are also things we do not do with it. We do not sell personal information. We do not share it for cross-context behavioural or targeted advertising. We do not rent, trade, or otherwise make our contact list available to anyone marketing their own products. And we do not make decisions about you by automated means that produce legal effects.

[COUNSEL] — those four sentences are commitments rather than descriptions, and they constrain what this company may later do without amending this policy and notifying investors. Confirm the company intends to be bound by all four.

Directly from you. When you use the contact panel, send an email, speak with us, complete an investor eligibility questionnaire, or sign investment documents or a lease.

From your advisers and representatives. Your accountant, attorney, investment adviser, or broker-dealer, where you have asked them to deal with us on your behalf. Your broker, your lender, or your agent, in a leasing or land transaction.

From service providers acting for us. The administration, accounting, banking, and document-signing providers described in Section 04 return information to us in the course of the work we engage them to do.

From your device. Our hosting provider records ordinary server request information when you load a page. This site sets only the cookies needed to make it work. It does not run advertising cookies, and it does not currently run third-party analytics.

⚠ That last sentence is a statement of fact about a site that has no analytics installed. Adding an analytics or advertising script to this site makes it false, and this section, Section 05, and the California disclosures in Section 06 all have to be rewritten in the same change — not afterwards.

From public and commercial sources. Business registries, property and title records, sanctions and watch lists, and — where relevant to a transaction and permitted by law — credit and background reports.

From counterparties in a transaction. Lenders, title companies, escrow agents, brokers, contractors, and the other parties to a deal give us information about the people involved in it as a matter of course.

We may combine information from these sources, and we may combine what we collect online with what we collect offline.

Within the Aurelian structure. Aurelian does not run a fund. Each building is developed by a partnership formed for that building alone, and information moves between the sponsor entity and the partnership you have an interest in so that the partnership can be administered. It does not move between partnerships, except in respect of a person who holds an interest in more than one.

With service providers who work for us. Accountants and tax preparers who produce the partnerships' tax filings and the annual schedules issued to members; partnership administrators; legal counsel; banks and escrow agents; electronic signature and document platforms; and the hosting, email, and IT providers that run this site and our correspondence. They receive only what they need for the work we engage them to do.

[COUNSEL] — confirm that each such provider is under a written agreement restricting its use of personal information to the services performed for us before that last sentence is published as drafted.

With other members of a partnership. A limited liability company’s operating agreement and the law of the state it is formed in give members certain rights to information about the company, which can extend to a list of members and their addresses. If you subscribe, another member may be entitled to see that you are one. [COUNSEL] — confirm what the operating agreement provides, and whether that entitlement is limited.

With counterparties to a transaction. Lenders, joint venture partners, prospective purchasers, title companies, and their advisers, in connection with financing, a sale, or the diligence that precedes either.

With regulators, and in response to legal process. The Securities and Exchange Commission, state securities regulators, taxing authorities, courts, and law enforcement, where we are required to respond or where we believe in good faith that we are. We may also share information to establish or defend a legal claim, to enforce an agreement, and to protect the rights and safety of Aurelian, its investors, and others.

With a successor to our business. If Aurelian, a partnership, or a building is sold, financed, or reorganised, information may pass to the counterparty and its advisers as part of that transaction and the diligence for it.

We do not sell personal information, and we do not share it for cross-context behavioural advertising.

You can stop the marketing emails. Follow the unsubscribe instructions in any promotional message, or ask us through the contact panel on this site. [COUNSEL] — a dedicated privacy address, and the second request method some state statutes require, are not published yet. We will still send the messages we owe you: a reply to your question, a notice under an operating agreement, a request for capital that has fallen due, a payment notice, and your annual tax schedule are not marketing and cannot be opted out of while you hold an interest.

You can control cookies in your browser. Most browsers can be set to refuse cookies or to warn you before one is set. Blocking them may stop parts of this site from working. Because this site sets only the cookies needed to serve it, there is no advertising or analytics tracking here to switch off.

Do Not Track and Global Privacy Control. Browser do-not-track signals are not uniform and we do not currently respond to them. A Global Privacy Control signal is an opt-out of sale and of targeted advertising; we do neither, so there is nothing for it to opt you out of. [COUNSEL] — revisit both sentences if analytics or advertising is ever added.

You can decline to give us information. Almost everything here is voluntary, and the consequence of declining is simply that we cannot do the thing it was needed for. The one hard case is eligibility: we cannot take an investment from someone who has not confirmed their financial eligibility to us in writing. That is a condition of the exemption the securities are offered under, and it cannot be waived.

You can ask us to correct or delete what we hold. Make the request through the contact panel on this site. [COUNSEL] — a dedicated privacy address, and the second request method some state statutes require, are not published yet. Sections 06 and 07 set out the rights that residents of particular jurisdictions have; we will honour a reasonable request from anyone, subject to the retention obligations described in Section 08.

6.1 California. If you are a California resident, the following describes our collection, use, and disclosure of personal information in the preceding twelve months.

We have collected the following categories of personal information as defined by the California Consumer Privacy Act: identifiers; personal information listed in the California customer records statute; characteristics of protected classifications, only where volunteered in a career inquiry; commercial information; internet or other electronic network activity information; approximate geolocation derived from an IP address; professional or employment information; education information; and sensitive personal information, being a Social Security or taxpayer identification number, a government identification number, and financial account details.

• The purposes we collect and use it for are in Section 02.
• The sources we collect it from are in Section 03.
• The categories of parties we disclose it to for a business purpose are in Section 04.
• How long we keep it, and why some of it cannot be deleted, is in Section 08.

We have not sold personal information and have not shared it for cross-context behavioural advertising, in the preceding twelve months or at any time. We use and disclose sensitive personal information only for the purposes permitted without a right of limitation under California law — to perform the services requested, to confirm investor eligibility, for security and fraud prevention, and to comply with legal obligations. We offer no financial incentives in exchange for personal information.

California residents may request that we disclose the personal information we have collected about you and the details listed above; correct inaccurate personal information; and delete personal information we hold, subject to the exceptions in the statute. Because we neither sell nor share personal information, and use sensitive personal information only for permitted purposes, there is no opt-out of sale or sharing and no right to limit for you to exercise. We will not discriminate against you for making any request.

Requests can be made through the contact panel on this site. [COUNSEL] — a dedicated privacy address, and the second request method some state statutes require, are not published yet. We will take reasonable steps to verify your identity before responding, and the steps will be more demanding where the information requested is sensitive. You may use an authorised agent, in which case we will ask for proof of their authority and may still verify your identity directly. California residents may also ask us once a year whether we have disclosed personal information to third parties for their direct marketing purposes; we have not.

[COUNSEL] — much of the information this company holds about investors is nonpublic personal information subject to the federal Gramm-Leach-Bliley Act and Regulation S-P, which is exempt from the CCPA. Confirm whether that exemption applies here, whether a separate financial privacy notice is required, and how the two documents should refer to each other.

6.2 Other states. If you are a resident of a state with a comprehensive consumer privacy statute — including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia — you may confirm whether we process your personal information, access it, obtain a portable copy, correct it, and request its deletion, in each case subject to the exceptions in your state’s statute and the retention obligations in Section 08. Rights to opt out of sale, targeted advertising, and profiling are available in principle and empty in practice, because we do none of the three.

Make a request through the contact panel on this site. [COUNSEL] — a dedicated privacy address, and the second request method some state statutes require, are not published yet. If we decline it, in whole or in part, we will tell you why, and you may appeal by replying to that response; we will respond to the appeal within the period your state’s statute allows and will tell you how to complain to your Attorney General if you remain dissatisfied.

[COUNSEL] — confirm the list of states and their respective rights, cure periods, and appeal deadlines as at the date this policy is published. The list changes every legislative session, and a stale one is a representation we cannot meet.

6.3 Nevada. Nevada residents may direct us not to sell covered information as defined by Nevada law. We do not sell it, and a request to that effect will be recorded.

This website is directed to tenants, brokers, landowners, and counterparties in the United States, and Aurelian's private offerings are made only in the United States. No securities are offered on this website, and none are offered in the European Economic Area or the United Kingdom; this site is not intended for use there.

If the EU or UK General Data Protection Regulation nevertheless applies to our processing of your personal data, we process it on one or more of these bases: because it is necessary to enter into or perform a contract with you; because it is necessary to comply with a legal obligation; because it is necessary for our legitimate interests in operating and securing our business, evaluating and administering an investment or a transaction, and preventing fraud; or because you have consented, in which case you can withdraw that consent at any time.

Where it applies, you have the rights to be informed, to access your data, to have it rectified, to have it erased, to restrict or object to its processing, and to data portability, each subject to exceptions. You can also complain to your supervisory authority — in the United Kingdom, the Information Commissioner's Office.

Requests can be made through the contact panel on this site. [COUNSEL] — a dedicated privacy address, and the second request method some state statutes require, are not published yet.

[COUNSEL] — this section is deliberately short because the company does not target these jurisdictions. If that changes, it needs a controller identity, a representative where one is required, transfer mechanisms, and retention periods, none of which are drafted here.

Accreditation records. An issuer must be able to show who it sold securities to and on what basis. An investor eligibility questionnaire, and anything sent with it, is kept whether or not you go on to invest, and a request to delete it cannot be honoured while we may need to demonstrate the exemption we relied on. [COUNSEL] — set the retention period, and confirm what happens to any supporting financial document that is sent to us.

Partnership and tax records. Subscription documents, the register of members, capital account records, distribution records, and tax filings are kept for the life of the partnership and for the period afterwards that tax and corporate law require. [COUNSEL] — retention schedule.

Correspondence and inquiries. Kept while a conversation is live and for a reasonable period afterwards, then deleted. If you ask us to delete an inquiry that led nowhere, we will.

Website records. Server request records are kept for the short period our hosting provider retains them, and are used for diagnostics and security rather than to build a profile of you.

Aurelian operates in the United States and its service providers are, so far as we are aware, located there. Information you give us is processed and stored in the United States, where the standard of data protection is not the same as in the European Economic Area, the United Kingdom, or Canada, and where information may be subject to access by government and law enforcement agencies under United States law. If you send us information from outside the United States, you are asking us to process it here.

We take reasonable measures to protect the information we hold, and access to investor information is limited to the people and providers who need it for the purposes described here. No transmission over the internet and no method of electronic storage is completely safe, and we cannot guarantee the security of anything you send us.

That is part of why accreditation is confirmed on a questionnaire rather than by collecting your financial records: the less of that material reaches us, the less of it there is to protect. Please do not send financial documents, account numbers, or a taxpayer identification number by ordinary email; ask first, and we will tell you where to send them. [COUNSEL] — name the secure channel here once one is in place.

This website is intended for adults, and so is everything it leads to. We do not knowingly collect personal information from anyone under sixteen. If you believe a child has given us information, tell us and we will delete it.

Following a link from this site can take you somewhere we do not operate — a professional network, a mapping service, a counterparty’s website, or a document platform. This Privacy Policy does not apply to any of them. Their practices are their own, and worth reading before you hand over anything.

Nothing in this Privacy Policy is an offer to sell or a solicitation of an offer to buy any security, no investment is being offered through this website, and nothing here modifies the terms of an offering. Any offer would be made only to a person with whom Aurelian has a pre-existing substantive relationship, and solely through the Private Placement Memorandum for that offering, which governs and should be read in full alongside the operating agreement and subscription documents for that partnership.

We may change this Privacy Policy from time to time. The revised version will be posted here with a new effective date, and where a change is material we will tell you to the extent the law requires it. Continuing to use this site after a change means you accept the updated policy.