This Privacy Notice is provided to you as a result of certain federal privacy notice and disclosure regulations and explains the manner in which EBFiveUSA.com, Pacific Coast USA Regional Center, LLC, and Clearwater Beach Resort Regional Center, LLC ("Regional Center"," "we," "our," or "us") collect, utilize and maintain nonpublic personal information about each of our investors. This Privacy Notice applies only to natural persons, grantor trusts or 401(k)/IRA investors (herein "Investors").We respect your right to privacy and are committed to maintaining and safeguarding nonpublic personal information about you. However, to manage our funds in a professional and efficient manner, we must from time to time obtain and disclose certain nonpublic personal information about you. To protect the confidentiality of such information while making the necessary disclosures, we have developed the privacy and security policies described below.Various laws and regulations use different terms and definitions for personal information of individuals that should be protected. Some laws and regulations consider only very limited types of information to be protected. Others consider much broader categories. This Privacy Notice applies to any personal information that is required under applicable law to be protected by us.If you are a corporate Investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal information on individuals connected to you for any reason in relation to your investment with us, this Privacy Notice will be relevant for those individuals whose information you share with us and you should transmit this document to such individuals or otherwise advise them of its content.​

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INFORMATION WE COLLECT

We may obtain personal information about you in connection with providing investment advisory services to you or to a fund in which you are invested or evaluating your request for such services or investment.We may collect the following types of personal information about you from the following sources:Information we receive from you through subscription agreements, investor questionnaires and other documents, such as your name, address, social security number, assets, income, tax identification number, state or national identification information, employment and amounts or types of your investments.Information about your transactions with us, our affiliates and others, such as your capital account balance, other financial account data and participation in other investments.Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms, device information such as an IP address, location information and any information captured via cookies, web beacons or similar tracking technologies.Information obtained from other third party sources that provide consumer data, such as information about your interests, demographic information, and marketing inferences.​

 

HOW WE USE INFORMATION WE COLLECT

We use your personal information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:To present, operate or improve our site and services;To authorize access to our sites and services;To verify your identity when you communicate with us or our service providers, agents or delegates to ensure compliance with our legal obligations;To respond to your requests, questions and comments and provide investor support;To communicate with you as necessary in connection with your investment, prospective investment, or former investment in our funds, which may be necessary to perform a contract with you;To provide, maintain, administer or expand our services, performing business analyses, or for other internal purposes;To comply with all applicable legal requirements;To enforce our subscription agreements and other agreements;To investigate possible fraud, violations of this Privacy Notice and/or attempts to harm our investors;We may aggregate or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any individual.​

 

HOW WE USE SENSITIVE PERSONAL INFORMATION

Subject to applicable laws, we may process sensitive personal information while doing business with you. Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (for example, information related to racial or ethnic origin, political opinions, religion or other beliefs, geolocation, health, criminal background, or identifiers such as social security number or driver's license number, passport numbers, state identification numbers, or account, credit card or debit card numbers) to us.The sensitive personal information that we process may include:A person's social security number, driver's license, state identification card, or passport number.The contents of a person's email, mail, or text messages where Regional Center is not the intended recipient of the communication.

 

​INFORMATION WE DISCLOSE

We will only disclose personal information to our affiliates and service providers as permitted by applicable law. In general, we may share your personal information with our affiliates (including those who are involved in the operation, service, administration or management of, or the sale of interests in, our funds) and to unaffiliated third party service providers, only as permitted by law or in connection with the management and administration of your investment, prospective investment, or former investment in a fund managed by us and accounts related to that investment. For example, we may share personal information we collect as described above in connection with the administration and operations of our funds (including disclosure to attorneys, accountants, service providers, technology providers, auditors or administrators). We may also disclose your personal information to governmental authorities when necessary and appropriate or pursuant to legal process, or self-regulatory organizations to the extent required by applicable law. We may share your personal information with a third party in connection with a sale or business transaction, including in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock. It is our practice to require parties that receive personal information from us to agree to use it only for the services required and as permitted by applicable law, and to require these parties by contract to maintain and protect the confidentiality of the personal information they process. We do not sell our Investors' personal information.

 

​INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Regional Center is based in the United States. Certain service providers and agents with which we share your information are located in the United States, India, China, Africa, United Arab Emirates, Canada, U.K. and others. The United States United States, India, China, Africa, United Arab Emirates, Canada, U.K. and others may not be regarded as providing the same level of protection for your information as your country of residence. In order to provide additional protection for your information, in certain circumstances, we have put in place appropriate safeguards, such as the standard contractual clauses for transfers of personal information to countries not considered adequate by the relevant data protection regulator.

 

​OUR SECURITY PROCEDURES

Any service provider receiving your personal information will be authorized to use such information only to perform the services required of them by our funds and their affiliates, and then only as permitted by applicable law. We restrict access to personal information to those employees of our funds who require access to provide services to our funds and their affiliates and investors. We maintain administrative, technical, physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public nonpublic personal information. Your right to privacy extends to all forms of contact with us, including telephone, written correspondence and electronic media.We are committed to safeguarding the nonpublic personal information of our investors and will adhere to the foregoing policies for both our current and former investors.

 

​DATA RETENTION

We retain personal information for as long as needed or permitted under applicable data protection law for the purposes for which is was obtained. Criteria used to determine our retention periods include: the duration of our relationship with you; the length of time necessary to complete a transaction; whether your nonpublic personal information is a sensitive type; whether you specifically consented to the retention of the information; and our legal, contractual or similar obligations to retain or delete the information.​

 

YOUR PRIVACY RIGHTS

Depending on where you are located and how or why your personal information was collected, you may have certain rights regarding the personal information we hold about you. These rights may include the right to: (1) know what personal information has been collected about you and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) request to restrict, object to, opt-out or limit our use of your personal information; and (5) obtain a copy of your personal information.Please note that we may require additional information from you to verify your identity before we respond to your request. If you would like to exercise any rights you may have under applicable local law, please contact us at info@ebfiveusa.com.​

 

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to change our privacy policies and this Privacy Notice at any time. This notice is intended to comply with the privacy provisions of applicable U.S. federal law and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you.​

 

HOW TO CONTACT US

If you have any specific questions about this Privacy Notice or would like to make an individual rights request regarding your personal information described above, you may contact us at info@ebfiveusa.com.