1. Introduction

At ACS Asset Holdings LLC (“ACS,” “we,” “us,” or “our”), along with our affiliates Anchorage Solutions and Intent Reality, we are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, share, and safeguard your data when you interact with our services, both online and offline.

This Policy applies to personal information collected through our website (www.acsassetholdings.com) and other communication channels used in connection with our real estate investment activities. By accessing or using our services, you acknowledge and agree to the terms outlined in this Privacy Policy.

ACS, along with Anchorage Solutions and Intent Reality, collects and processes personal information to comply with regulatory requirements, improve user experience, and provide accredited investors with relevant investment opportunities. Our goal is to ensure transparency and control over your data while adhering to applicable privacy laws and industry standards.

If you have any questions or concerns about this Privacy Policy, please contact us using the details provided in the Contact Information section.

2. Information We Collect

ACS Asset Holdings LLC (“ACS”) collects only the essential personal information required to verify investor eligibility and facilitate communication. The following categories of personal data may be collected:

2.1 Categories of Personal Information Collected

• Full Name
• Email Address
• Phone Number
• Full Address
• Self-reported Accredited Investor Status

ACS does not collect sensitive personal data such as Social Security Numbers, government-issued identification, or financial account details through its website

2.2 How We Collect Your Information

ACS obtains personal information through the following means:

• Direct Submission – When users voluntarily provide information through our website’s registration form or other official communication channels.
• Regulatory Compliance Processes – When verifying investor eligibility as required by applicable laws and financial regulations.

All collected data is securely stored and used solely for the purposes outlined in this Privacy Policy

3. Purpose of Data Collection and Processing

ACS does not use personal data for unrelated marketing or advertising purposes and strictly adheres to data privacy regulations. ACS Asset Holdings LLC (“ACS”) collects and processes personal information strictly for investment facilitation and regulatory compliance. The primary purposes of data collection include:

3.1 Self-Reported Investor Status and Eligibility Verification

• To allow users to self-report their accredited investor status under Rule 501 of Regulation D under the Securities Act of 1933, as amended during the registration process.
• Self-reported accreditation does not constitute verification, and users are not automatically considered accredited investors by ACS.
• Accredited investor status is only confirmed after appropriate verification through a third-party service (e.g., VerifyInvestor.com) or other acceptable methods, such as:
  • A letter from a certified public accountant (CPA), licensed attorney, or registered investment advisor (RIA).
  • Submission of supporting financial documents, such as tax returns or brokerage account statements, directly to the verifying entity.
• Users must complete the verification process before gaining access to investment opportunities.

3.2 Communication and Investor Support

• To respond to inquiries about ACS investment opportunities.
• To provide notifications, confirmations, and updates related to investment offerings.
• To send administrative messages, including account status updates and compliance notices.

3.3 Legal and Regulatory Compliance

• To fulfill obligations under federal and state securities regulations, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
• To maintain accurate investment records in accordance with regulatory requirements.

3.4 Business Operations and Security

• To detect and prevent fraudulent activities related to investment inquiries.
• To safeguard ACS’s website and investor communications against unauthorized access.

4. Information Sharing and Third-Party Disclosure

ACS Asset Holdings LLC (“ACS”) values your privacy and only shares personal information when necessary to facilitate investment operations, comply with regulatory obligations, or ensure the security of our services. ACS does not sell personal data to third parties.

4.1 Third Parties with Whom ACS Shares Data

Personal information may be shared only with the following categories of third parties:

       1. Affiliated Companies

ACS may share limited personal information with its affiliates, Anchorage Solutions and Intent Reality, in connection with investment operations, due diligence, and regulatory compliance. These entities follow the same data protection standards outlined in this Privacy Policy.

       2. Accredited Investor Verification Services

ACS partners with third-party verification providers (e.g., VerifyInvestor.com) to confirm accredited investor status. Users are responsible for submitting required documents directly to the verification service, not through the ACS website.

       3. Regulatory and Legal Entities

Information may be disclosed to government agencies, regulators, or law enforcement if required to comply with:

• Federal and state securities laws.
• Anti-money laundering (AML) and know-your-customer (KYC) regulations.
• Court orders, subpoenas, or legal investigations.

        4. Financial Institutions and Payment Processors

If an investment transaction requires fund transfers, ACS may share limited user details with banks or financial institutions only as necessary to facilitate the transaction.

         5. Security and Fraud Prevention Partners

ACS may collaborate with fraud detection and cybersecurity firms to:

• Prevent unauthorized access to user accounts.
• Investigate suspicious activity or fraudulent investment attempts.

          6. Professional Service Providers

ACS may share limited personal data with legal, accounting, and compliance consultants to ensure adherence to regulatory requirements.

4.2 Situations Where ACS May Disclose Information

ACS will only disclose personal information in the following situations:

• To fulfill regulatory requirements, including accredited investor verification.
• To protect ACS’s legal interests, including fraud prevention or dispute resolution.
• To complete a business transaction, such as a merger, acquisition, or restructuring, provided that appropriate confidentiality measures are in place.

 ACS does not share user data for marketing purposes and ensures that any third-party recipient maintains strict data protection policies in accordance with applicable regulations.

5. Data Security Measures

ACS Asset Holdings LLC (“ACS”) prioritizes the security of Users’ personal information and employs industry-standard security measures to protect data from unauthorized access, disclosure, alteration, or destruction.

6.1 Technical Safeguards

ACS implements the following security controls to protect User data:

• Encryption: Personal information is stored using encryption protocols to prevent unauthorized access.
• Secure Storage: Data is stored in secure systems with controlled access, including cloud-based and on-premise servers with appropriate security measures.
• Access Controls: Only authorized personnel with a legitimate business need can access sensitive data.
• Secure Transmission: Data transfers are protected using encryption and secure protocols (e.g., HTTPS, TLS).

6.2 Organizational Protocols

ACS has established internal procedures to ensure proper handling of sensitive data:

• Employee Training: Staff members undergo regular training on data protection and security best practices.
• Incident Response Plan: ACS has a structured plan to detect, respond to, and mitigate security breaches.
• Third-Party Security Compliance: Vendors and service providers handling User data must comply with ACS’s security standards and data protection requirements.

6.3 Reporting Security Concerns

Users who suspect unauthorized access, data breaches, or other security incidents related to ACS services should report them immediately using the contact information provided in Section 9 – Contact Information. ACS investigates all reported incidents and takes appropriate action to mitigate risks.

7. Data Retention and Deletion

ACS Asset Holdings LLC (“ACS”) retains personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

7.1 Data Retention Periods

The retention period for each category of personal information varies based on business, regulatory, and legal requirements. ACS follows these general guidelines:

• Registration Information (Full Name, Email, Phone Number, State of Residence, Self-Reported Accredited Investor Status)
  • Retained for the duration of the User’s engagement with ACS and for five (5) years after the last interaction or as required by applicable laws.
• Accredited Investor Verification Records (Collected by Third Parties, Not by ACS)
  • Retained by the third-party verification provider (e.g., VerifyInvestor.com) as per their policies and applicable regulations.
  • ACS does not store copies of these verification documents.
• Communication Records (Emails, Phone Inquiries, Customer Support Requests)
  • Retained for three (3) years for operational and legal compliance purposes.
• Security and Fraud Prevention Logs
  • Retained for up to five (5) years, unless required for ongoing investigations or legal actions.

7.2 Data Deletion Requests

Users may request deletion of their personal data by contacting ACS (see Section 9 – Contact Information). However, certain data cannot be deleted due to regulatory or legal obligations, such as:

• Compliance with securities laws requiring retention of investment-related records.
• Obligations under anti-money laundering (AML) laws and other financial regulations.
• Retention needed for fraud prevention or security investigations.

If ACS is unable to fulfill a deletion request due to legal requirements, Users will receive an explanation outlining the reason for data retention.

8. Policy Updates and Notifications

ACS Asset Holdings LLC (“ACS”) may update this Privacy Policy periodically to reflect changes in legal requirements, industry practices, or business operations.

Updates to this Privacy Policy will be communicated through one or more of the following methods:

• Website Notification: A banner or notice posted on the ACS website.
• Email Notification: Users who have provided an email address will receive a summary of significant changes.
• Account Dashboard Notification: If applicable, a message will be displayed within the User’s account.

The “Effective Date” at the top of this Privacy Policy will be updated to reflect the latest revision.

9. Contact Information

For any inquiries, concerns, or requests regarding these Terms and Conditions, or for general questions related to ACS Asset Holdings LLC, please use the contact details below:

Company Information

ACS Asset Holdings LLC
3060 Valleywood Drive, Kettering, Ohio 45429

Communication Channels

Email: [email protected]
Phone: (937) 952-5100
Website: www.acsassetholdings.com

Business Hours

Monday – Friday: 8:00 AM – 5:00 PM (EST)
Closed on weekends and U.S. federal holidays.

For matters requiring formal correspondence, ACS recommends using written communication via email or mail. If your request relates to investment eligibility, regulatory compliance, or legal concerns, please specify your inquiry clearly to facilitate a prompt and accurate response.