Privacy Policy

1. Who We Are

This Privacy Policy (“Policy”) describes how Always Improving LLC, a North Carolina limited liability company (“Company,” “we,” “us,” or “our”), collects, uses, shares, and protects your personal information when you access or use the website, applications, and services available at monthavencapital.com and any related subdomains (collectively, the “Platform”).

Always Improving LLC is the data controller for all personal information collected through the Platform. We determine the purposes and means of processing your personal information and are responsible for compliance with applicable data protection laws.

Certain services accessible through the Platform are provided by our authorized affiliates:

• Monthaven Brokerage LLC — Licensed real estate brokerage services
• Monthaven Capital Inc. — Capital advisory and co-sponsorship services

These affiliates access personal information solely as authorized by Always Improving LLC under their respective technology license agreements. They do not independently own, control, or make decisions about your personal information. For purposes of data protection law, they act as data processors on behalf of Always Improving LLC.

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Name, email address, phone number, mailing address, and company or entity name
• Professional Information: Professional title, license numbers, brokerage affiliations, and accredited investor status
• Deal Submissions: Property details, financial data (T-12 operating statements, rent rolls, pro formas), offering memoranda, and related materials
• Investment Information: Investment preferences, capital commitment amounts, risk tolerance, and investment history
• Communications: Messages, inquiries, feedback, and correspondence sent through the Platform
• Identity Verification: Government-issued identification, accredited investor documentation, and other verification materials
• Contract Data: Signatures, agreed terms, and information provided in connection with executing agreements through the Platform

2.2 Information Collected Automatically

• Device Information: IP address, device type, operating system, browser type and version, and unique device identifiers
• Usage Data: Pages visited, features used, time spent on the Platform, navigation patterns, click data, and search queries
• Communication Metadata: Call logs, SMS timestamps, message delivery status, and communication routing data
• Location Data: General geographic location derived from IP address (we do not collect precise GPS location)
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixels, and similar technologies (see Section 8)

2.3 Information From Third Parties

• Public Records: Property ownership records, tax assessor data, and other publicly available real estate information
• Identity Verification Services: Results from identity and accreditation verification providers
• Communication Providers: Call and SMS delivery confirmations from telecommunications infrastructure providers

3. How We Use Your Information

3.1 Platform Operations

• Provide, maintain, and improve the Platform and its features
• Process account creation and manage your access
• Facilitate deal submissions, investor introductions, and transaction support
• Operate communication tools (calls, SMS, email) within the Platform
• Execute and manage contracts and agreements

3.2 Analytics & Intelligence

• Generate market analytics, scoring models, and investment insights using AI and machine learning systems
• Develop and improve underwriting algorithms, property valuation models, and deal analysis frameworks
• Create aggregated, de-identified datasets for research and Platform improvement

3.3 Communications

• Send transactional communications (deal updates, contract notifications, account alerts)
• Send marketing and promotional communications (with your consent, where required)
• Respond to your inquiries and provide customer support

3.4 Legal & Compliance

• Comply with applicable laws, regulations, and legal processes
• Enforce our Terms of Service and other agreements
• Protect against fraud, unauthorized access, and other security threats
• Verify accredited investor status as required by securities regulations
• Maintain records as required by state real estate commission rules

4. Data Ownership

4.1 All Platform Data is Owned by Always Improving LLC. All data collected, generated, processed, stored, or derived through the Platform, including but not limited to user profiles, lead records, call logs, communication histories, deal submissions, investor records, property analytics, scoring outputs, market intelligence, aggregated datasets, and AI-generated insights (collectively, “Platform Data”), is the exclusive property of Always Improving LLC.

4.2 No Affiliate Ownership. No affiliate of Always Improving LLC, including Monthaven Capital Inc. and Monthaven Brokerage LLC, independently owns or controls any Platform Data. These affiliates access Platform Data solely under the terms of their respective technology license agreements with Always Improving LLC. Upon termination of any such license, all data access rights are immediately and automatically revoked.

4.3 Derived Data. Any data, analytics, insights, models, scores, or other outputs generated by the Platform using your information (including through AI and machine learning processing) are the exclusive property of Always Improving LLC. You have no ownership interest in derived data, even if it was generated using information you submitted.

4.4 Non-Portability of Aggregated Data. Aggregated data, market intelligence, analytics, trend reports, scoring models, and proprietary platform insights are not exportable or transferable. Individual users may request access to their own personal profile data (see Section 10), but aggregated or derived datasets are not available for export.

5. How We Share Your Information

5.1 We Do Not Sell Your Personal Information. We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.

5.2 Authorized Affiliates. We share personal information with our authorized affiliates solely for the purpose of providing services you have requested:

• Monthaven Brokerage LLC — to facilitate licensed brokerage services, including deal introductions, investor matching, offering memorandum distribution, and transaction support. Monthaven Brokerage LLC accesses this data under a technology license from Always Improving LLC and does not independently own or control it.
• Monthaven Capital Inc. — to facilitate capital advisory, co-sponsorship, and deal execution services. Monthaven Capital Inc. accesses this data under a technology license from Always Improving LLC and does not independently own or control it.

5.3 Service Providers. We share personal information with third-party service providers who assist Always Improving LLC in operating the Platform, including:

• Cloud hosting and infrastructure providers
• Email and communication platforms
• SMS and telephony providers
• Payment processors
• Electronic signature providers
• Analytics and monitoring tools
• Identity and accreditation verification services

All service providers are contractually obligated to use your information only for the purposes of providing services to Always Improving LLC and to maintain appropriate confidentiality and security measures.

5.4 Legal Requirements. We may disclose your information when required by law, court order, subpoena, or governmental regulation, or when we believe in good faith that disclosure is necessary to:

• Comply with applicable law or legal process
• Protect the rights, property, or safety of Always Improving LLC, our users, or others
• Enforce our Terms of Service or other agreements
• Detect, prevent, or address fraud, security, or technical issues

5.5 Business Transfers. In the event of a merger, acquisition, reorganization, or sale of all or substantially all of Always Improving LLC's assets, your personal information may be transferred to the acquiring entity. We will provide notice of any such transfer and any choices you may have.

5.6 With Your Consent. We may share your information in other circumstances with your explicit consent.

6. SMS/Text Messaging Privacy

If you opt in to receive text messages through the Platform:

• Messages are transmitted through telecommunications infrastructure owned and operated by Always Improving LLC
• Message content and metadata (timestamps, delivery status, phone numbers) are Platform Data owned by Always Improving LLC
• Message frequency varies based on your engagement and deal activity
• Message and data rates may apply depending on your carrier plan
• You may opt out at any time by replying STOP to any message
• For help, reply HELP or contact info@monthavencapital.com

We do not sell, rent, or share your phone number with third parties for their own marketing purposes.

Supported carriers include major U.S. carriers. Carrier terms and conditions may apply.

7. Data Retention

7.1 Active Accounts. We retain your personal information for as long as your account is active and as necessary to provide Platform services.

7.2 After Account Termination. Following account termination, we retain your personal information as follows:

7.3 Legal Holds. We may retain information beyond standard retention periods if required by a legal hold, pending litigation, regulatory investigation, or other legal obligation.

8. Cookies & Tracking Technologies

We use cookies and similar tracking technologies to:

• Remember your preferences and account settings
• Authenticate your identity and maintain session security
• Analyze Platform usage and performance
• Improve user experience and Platform functionality
• Deliver relevant content and communications

Types of Cookies:

You can control cookies through your browser settings. Disabling essential cookies may affect Platform functionality. Disabling analytics or marketing cookies will not affect core Platform access.

9. Data Security

We implement administrative, technical, and physical safeguards to protect your personal information, including:

• Encryption: Data encrypted in transit (TLS/SSL) and at rest
• Access Controls: Role-based access controls limiting data access to authorized personnel and systems
• Authentication: Multi-factor authentication and secure session management
• Monitoring: Automated security monitoring and intrusion detection
• Audit Logging: Comprehensive logging of data access and modifications
• Contractual Protections: All affiliates and service providers are bound by confidentiality agreements and data processing terms

No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

If we become aware of a data breach affecting your personal information, we will notify you in accordance with applicable breach notification laws.

10. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

10.1 Access. You may request a copy of the personal information we hold about you.

10.2 Correction. You may request correction of inaccurate or incomplete personal information.

10.3 Deletion. You may request deletion of your personal information, subject to our retention obligations under Section 7 and any surviving contractual obligations.

10.4 Opt-Out of Marketing. You may opt out of marketing communications at any time by:

• Clicking the “unsubscribe” link in any marketing email
• Replying STOP to any SMS message
• Contacting us at the address below

10.5 Data Portability. You may request a copy of your personal profile data in a commonly used electronic format. This right applies only to your personal profile data — not to aggregated data, derived insights, scoring outputs, market intelligence, or other Platform Data owned by Always Improving LLC (see Section 4.4).

10.6 Withdrawal of Consent. Where processing is based on your consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

10.7 To Exercise Your Rights. Contact us at info@monthavencapital.com or the address listed in Section 14. We will respond to verified requests within 45 days (or as required by applicable law).

11. California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You have the right to know what personal information we collect, use, disclose, and sell (we do not sell personal information)
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions
• Right to Correct: You have the right to request correction of inaccurate personal information
• Right to Opt Out of Sale/Sharing: We do not sell or share (as defined by the CCPA) your personal information
• Non-Discrimination: We will not discriminate against you for exercising your CCPA rights

Categories of Personal Information Collected: Identifiers; professional information; commercial information; internet/electronic activity; geolocation data; inferences drawn from the above.

Business Purpose for Collection: As described in Section 3.

Categories of Third Parties with Whom We Share: As described in Section 5.

To submit a data rights request, visit our Data Rights Request page, or contact us at info@monthavencapital.com.

12. Other State Privacy Laws

If you are a resident of Virginia, Colorado, Connecticut, Utah, or other states with comprehensive privacy legislation, you may have similar rights to those described in Sections 10 and 11. Contact us to exercise these rights.

We do not engage in “targeted advertising” or “profiling” as defined under these state laws for purposes that would trigger additional opt-out rights.

13. Children

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

14. Contact

If you have questions about this Privacy Policy or wish to exercise your data rights, contact:

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated Policy on the Platform with a new effective date.

For material changes that affect how we use your personal information, we will make reasonable efforts to provide additional notice via email or Platform notification.

Your continued use of the Platform after any modification constitutes your acceptance of the modified Policy.