Privacy Policy
How SANTE Realty Investments collects, uses, and protects your personal information.
Effective Date: March 1, 2026 | Governing Law: State of Arizona
Table of Contents
Introduction
SANTE Realty Investments, LLC and its affiliates (collectively, "SANTE," "we," "us," or "our") are committed to protecting the privacy and confidentiality of personal information entrusted to us by our investors, prospective investors, Registered Investment Advisor ("RIA") partners, and visitors to our website. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website at santerealty.com (the "Site"), interact with our investment platforms, or engage with our team in connection with our investment funds, including the SANTE Legacy Protection Fund LP and Ground Lease Income Fund LP.
By accessing or using the Site, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please discontinue use of the Site immediately.
Information We Collect
We collect information that you provide directly to us, information collected automatically through your use of the Site, and information obtained from third-party sources.
Information You Provide Directly. When you contact us, request information about our investment offerings, submit an investor inquiry, or engage with our team, we may collect the following categories of personal information: your full legal name, email address, telephone number, mailing address, employer and job title, accredited investor status and self-certification, investment experience and objectives, net worth and income information (as required for accredited investor verification under Regulation D), RIA firm name, CRD number, and regulatory registration details (for RIA partners), and any other information you choose to provide in correspondence or through our contact forms.
Information Collected Automatically. When you visit the Site, we automatically collect certain technical information, including your IP address, browser type and version, operating system, referring URL, pages viewed, time and date of your visit, time spent on each page, and other diagnostic data. We use analytics services to help us understand Site usage patterns.
Cookies and Similar Technologies. We use cookies, web beacons, and similar tracking technologies to enhance your experience on the Site. Cookies are small data files stored on your device that help us remember your preferences and understand how you interact with the Site. You may control the use of cookies through your browser settings; however, disabling cookies may limit your ability to use certain features of the Site.
Information from Third Parties. We may receive information about you from third-party sources, including identity verification services used for accredited investor verification, RIA partners who refer prospective investors to our funds, fund administrators and service providers involved in fund operations, and publicly available sources such as SEC filings and FINRA BrokerCheck.
How We Use Your Information
We use the information we collect for the following purposes:
Investor Communications. To respond to your inquiries, provide information about our investment strategies and fund offerings, send periodic investor updates, distribution notices, and fund performance reports, and facilitate subscription and redemption processes.
Regulatory Compliance. To verify accredited investor status as required under Rule 506(c) of Regulation D of the Securities Act of 1933, comply with anti-money laundering ("AML") and know-your-customer ("KYC") requirements, fulfill our obligations under applicable federal and state securities laws, and maintain records as required by regulatory authorities.
Fund Administration. To process capital contributions and distributions, prepare and deliver tax documents including Schedule K-1s, maintain accurate investor records and capital account statements, and coordinate with fund administrators, auditors, and legal counsel.
Site Operations and Improvement. To operate, maintain, and improve the Site, analyze usage trends and user preferences, protect against unauthorized access and security threats, and ensure compliance with our Terms of Use.
RIA Partner Program. To administer the Co-GP equity stake joint venture structure, facilitate pro-rata allocation of investment opportunities, provide RIA partners with reporting and compliance documentation, and coordinate investor communications through RIA channels.
How We Share Your Information
We do not sell your personal information to third parties. We may share your information with the following categories of recipients, solely for the purposes described in this Privacy Policy:
RIA Partners. If you were referred to SANTE through a Registered Investment Advisor, we may share relevant investment information and account details with your RIA to facilitate advisory services and reporting.
Fund Administrators and Service Providers. We engage third-party fund administrators, transfer agents, custodians, and other service providers who require access to investor information to perform services on our behalf. These service providers are contractually obligated to protect the confidentiality of your information and to use it only for the purposes for which it was disclosed.
Legal and Compliance Counsel. We may share information with our legal counsel, compliance consultants, and auditors as necessary to comply with applicable laws, regulations, and legal processes.
Regulatory Authorities. We may disclose information to the Securities and Exchange Commission ("SEC"), the Financial Industry Regulatory Authority ("FINRA"), state securities regulators, and other governmental authorities as required by law or in response to lawful requests.
Business Transfers. In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
Data Security and Retention
We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption of sensitive data in transit and at rest, access controls limiting information access to authorized personnel, regular security assessments and monitoring, and secure data storage with redundant backup systems.
Despite our efforts, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your information.
We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. For current and former investors, we retain records for a minimum of seven (7) years following the termination of the investor relationship, or longer if required by applicable law.
California Consumer Privacy Act (CCPA) Rights
If you are a California resident, you have certain rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA/CPRA"), subject to certain exceptions:
Right to Know. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which your information was collected, the business or commercial purpose for collecting your information, and the categories of third parties with whom we share your information.
Right to Delete. You have the right to request the deletion of your personal information, subject to certain exceptions, including where retention is necessary to complete a transaction, comply with a legal obligation, or exercise or defend legal claims.
Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
Right to Opt-Out. You have the right to opt out of the sale or sharing of your personal information. As noted above, we do not sell your personal information.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA/CPRA rights.
To exercise any of these rights, please contact us at [email protected] or call +1 (480) 398-4954. We will verify your identity before processing your request and respond within 45 days, as required by law.
Children's Privacy
The Site is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Effective Date" at the top of this page and, where appropriate, notify you by email or through a notice on the Site. Your continued use of the Site after any changes to this Privacy Policy constitutes your acceptance of the updated policy.
Contact Us
If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your information is handled, please contact us:
**SANTE Realty Investments, LLC** 4343 N. Scottsdale Road, Suite 150 Scottsdale, AZ 85251
Email: [email protected] Phone: +1 (480) 398-4954