Privacy Policy.
Effective June 3, 2026 · Last updated June 3, 2026
Overview
This Privacy Policy (“Privacy Policy”) explains the personal information that REtokens Capital LLC, a Delaware limited liability company (the “Company,” “we,” “us,” or “our”) collects about you when you access or use our Site or Services, or interact with us in response to an email or other outreach from us or through any third-party application process. It also explains how we may use or disclose the personal information that we collect about you.
REtokens Capital LLC is a broker-dealer registered with the U.S. Securities and Exchange Commission (“SEC”), a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), and a wholly-owned subsidiary of REtokens USA Inc. We operate an SEC-registered alternative trading system (“ATS”).
This Privacy Policy applies whenever you access or use any of our Site or Services, download anything from our Site, or interact with us in response to an email, request for information, or other outreach from us or through any third-party application process. It does not govern information you choose to exchange directly with other Users of the Site, as we have no direct control over the collection or use of that information. Please use appropriate precautions in sharing your information with such Users.
In addition to this Privacy Policy, your relationship with the Company is also governed by our Terms of Service and any account, offering, or transaction documents you may enter into in connection with making an investment through the REtokens Capital marketplace. If you do not understand or agree with the terms of this Privacy Policy and the Terms of Service, please do not access or use any of the Site or Services.
Some Definitions
The following are definitions for some terms used in this Privacy Policy:
- “Affiliate” means an entity that controls, is controlled by, or is under common control with the Company, whether the control results from equity ownership, contract, overlapping management, or otherwise. The Company's parent is REtokens USA Inc.
- “ATS” means the SEC-registered alternative trading system operated by the Company.
- “Content” refers to all text, images, photographs, graphics, logos, illustrations, descriptions, data, tools, features, pages, and other materials provided on the Site, as well as the selection, assembly, arrangement, “look and feel,” and design of our Site.
- “Marketplace” means the investment marketplace and related portal operated by or for the Company through which securities offerings are made available.
- “Services” means the Content, products, or services offered on or through the Site, including the Marketplace and the ATS.
- “Site” refers, together and collectively, to the domains and subdomains of our website at retokenscapital.com.
- “Token” means a token that is a digital representation of indirect ownership in real estate.
- “User” means anyone who accesses and/or uses any of our Site or Services.
- “We,” “us,” and “our” refer to the Company and its Affiliates.
Your Consent
By using or accessing any of our Site or Services, downloading anything from our Site, or interacting with us in response to an email, request for information, or other outreach from us or through any third-party application process, you agree to the terms of this Privacy Policy and consent to the collection, use, and sharing of your personal information subject to and consistent with the terms of this Privacy Policy and applicable laws and other notices you may receive from us. If you do not understand or do not agree with the terms of this Privacy Policy, please do not use the Site. We may also ask you to indicate your consent more formally by checking a box or by taking an affirmative action within the Site. If you have any questions or concerns regarding this Privacy Policy, you should contact us at privacy@retokenscapital.com.
Changes to this Policy
This Privacy Policy is subject to change. When we make a change to the Privacy Policy, we will post the most current version of the policy here. Each time you visit any of our Site or Services, download anything from our Site, or interact with us in response to an email, request for information, or other outreach from us or through any authorized third-party application process, the most current version of our Privacy Policy will apply.
Regulation S-P / GLBA Privacy Notice (Consumer Financial Information)
Because REtokens Capital LLC is a broker-dealer, this section provides the privacy notice required by the federal Gramm-Leach-Bliley Act (“GLBA”) and SEC Regulation S-P regarding nonpublic personal information about our customers and consumers. This section supplements the rest of this Privacy Policy and controls with respect to nonpublic personal financial information.
Information we collect
We collect nonpublic personal information about you from the following sources: (1) information we receive from you on applications, subscription documents, or other forms (such as your name, address, Social Security or tax identification number, date of birth, income, net worth, and accreditation status); (2) information about your transactions with us, our Affiliates, or others (such as your account balances, holdings, and transaction history); and (3) information we receive from consumer-reporting agencies, identity-verification services, and other third parties in connection with our anti-money-laundering, “Know Your Customer,” and suitability obligations.
Information we disclose
We do not disclose nonpublic personal information about our customers or former customers to nonaffiliated third parties except as permitted or required by law. Permitted disclosures include, for example, disclosures: to service providers and financial institutions that perform services for us (such as clearing, custody, escrow, identity verification, and technology providers); to issuers and their agents to effect, administer, or enforce a transaction you request or authorize; to regulators, self-regulatory organizations, and law-enforcement or government authorities as required; and as otherwise permitted under Regulation S-P.
Your right to opt out
We do not sell your nonpublic personal information. The law permits you to opt out of certain sharing of nonpublic personal information with nonaffiliated third parties for those parties' own marketing purposes. To exercise an opt-out right, contact us at privacy@retokenscapital.com. Your opt-out will not limit disclosures we are permitted or required to make to service the relationship, complete transactions you request, or comply with law.
How we protect your information (Safeguards Rule)
We maintain physical, electronic, and procedural safeguards designed to protect the nonpublic personal information we collect, consistent with the Regulation S-P Safeguards Rule. We restrict access to such information to those who need it to provide products or services to you or to fulfill legal and regulatory obligations.
Delivery of this notice
We will provide this privacy notice when you establish a customer relationship with us and annually thereafter for as long as you remain a customer, as required by Regulation S-P. We may provide the notice electronically where you have consented to electronic delivery.
Personal Information We Collect
To help us provide the Services, we collect personal information about you through several means.
How we collect personal information
Direct means. We collect personal information from you directly by asking for it when you open an account or in other instances when you contact us or access or use any of our Site or Services. In fact, various laws require that we collect some of the kinds of personal information we ask for, such as anti-fraud / anti-money-laundering laws and “Know Your Customer” obligations. In addition to personal information that we are required to obtain from you by law, we may ask you for other personal information that you can choose, at your option, to provide or withhold, and any such information provided will be subject to this policy.
Automatic or passive means. Whenever you visit, use, access, or interact with any of our Site or Services, we use “cookies” and tracking technologies (further explained below) to collect data about you and your activities on our Site automatically or passively. These help us better understand how our Users navigate the Site, learn what content is viewed, and administer and improve our Site.
Third-party sources. We may obtain information about you from various third parties, including: (1) service providers we engage to perform functions on our behalf, such as verifying the identities of Users; (2) analytics providers; and (3) advertising, social media, and market-research providers and partners, including for referral purposes.
Types of information we collect
Personal information. The personal information we collect from or about you may include, but is not limited to: your name, residential and business address, email address, citizenship, telephone number, Social Security or tax identification number, date of birth, employment status, and employer; copies of your correspondence via email, phone, or social media if you contact us; information needed to grant us access to your accounts on third-party websites or applications; your username and password; and information about you individually that does not identify you, such as your investment history and experience, investment portfolio, and educational or professional history.
Personal financial information. If you choose to invest through the Marketplace, we may collect information including, but not limited to: financial information, including your Social Security number, income, and net worth; information to confirm your place of residence; information about your bank accounts or other sources of payment; your blockchain wallet address, wallet type, Token reference information, and date/time stamps; information to confirm your relationship with other parties associated with the Site or Services; your investment experience, objectives, and preferences, as well as information to establish whether you are an “accredited investor”; access credentials you establish; information about your relationship to or ownership in any entity that uses our Services; and your preferences for receiving, and how you engage with, our marketing communications.
Blockchain. We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of Tokens, which may then be associated with other information you have provided to us. Your transactions through the Services may be recorded on a blockchain and associated with your wallet ID. Any information that you attach to a blockchain operation may be viewed by the public. Due to the nature of blockchain technology, information recorded on a blockchain cannot practically be corrected or revised.
Non-identifiable and aggregated information. We or our service providers may automatically collect certain information when you access or interact with our Site or Services, including: your IP address or other unique identifier; the device type, browser, browser settings, and operating system you use; your mobile device's advertising identifier if you access the Site from a mobile device; and information about your interaction with our Site (dates and times of visits, pages and features used, time spent, emails opened or clicked, and other websites you may visit from our Site). We collect this information through cookies and similar technologies, and we may use Google Analytics for data-analytics purposes. You can find more information on how Google uses data at www.google.com/policies/privacy/partners/.
We may compile personal and other information on an aggregate basis that does not identify you individually and may share such aggregated information with third parties for the purposes specified in this Privacy Policy and for any other lawful purpose.
Combining information
We may combine personal information we collect from or about you directly with other information, including personal information we obtain about you from third-party sources or that we automatically collect through our Site or Services.
How We Use Personal Information We Collect
We use personal information that we collect from or about you to:
- Deliver our Services to you.
- Meet and enforce legal and regulatory requirements, including determining your eligibility to invest, identity verification, anti-money-laundering, and “Know Your Customer” protocols.
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- Protect against, investigate, and deter fraudulent, unauthorized, and illegal activity.
- Personalize your experience on our Site or when engaging with us.
- Provide advertising, including targeted advertising, to promote our Services, consistent with applicable law and FINRA communications rules.
- Perform analytics about your access to and use of our Site, Services, and advertisements.
- On a de-identified, aggregated basis, analyze how the Services are used to understand traffic patterns and improve the Services.
- Communicate with you, such as through email or text messages, to provide information and updates about us and our Services, and to respond to your comments and questions.
With Whom We Share Personal Information We Collect
Without your consent, we do not rent, sell, or share personal information with unrelated third parties, except as necessary to complete a transaction or provide a service you have requested, or as provided in this Privacy Policy.
Subject to the terms of this Privacy Policy and applicable law, we may share personal information with the following categories of third parties: the issuers of offerings you invest in; our Affiliates (each of which is also bound by the terms of this Privacy Policy); government agencies and regulators, as required by laws and regulations; wallet providers, to facilitate transactions; public blockchains, on which transactions are recorded and associated with your wallet ID; and our service providers (including database administrators, cloud-computing services, advertising services, data analysts, identity-verification services, accountants, auditors, clearing and custody providers, payment processors, and escrow partners).
We may also transfer personal information to a third party: in the event of a change of control (such as a merger, reorganization, or sale of assets, including in bankruptcy), in which case we will use reasonable efforts to require the transferee to use the information consistent with this Privacy Policy; and to meet legal obligations or to protect our customers, the security of our Services, or our rights or property. The privacy practices of third parties with whom we share information are governed by those third parties' own policies, for which we have no responsibility.
Aggregated / de-identified information. Collected personal information may be aggregated and/or de-identified, and we may share such information with third-party providers to deliver products, services, and content better tailored to Users and for our own business purposes where permitted by law.
How We Safeguard Personal Information We Collect
Your account with us is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately, limiting access to your devices and browser, and signing off after you have finished.
We are committed to safeguarding the confidentiality of your information but cannot guarantee its security. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we (1) encrypt information we store, (2) transmit information via https, and (3) limit access to authorized employees, contractors, and third parties who need it to operate, develop, or improve our Site or Services or to facilitate provision of our Services. No security system can prevent all potential breaches. If you believe your information may not be secure, please contact us immediately at privacy@retokenscapital.com.
You are solely responsible for keeping any third-party wallet and its private keys secure, and you should never share your wallet credentials with anyone. The private keys necessary to access a third-party wallet are held solely by you. The Company has no ability to help you access or recover your private keys.
Your Choices Regarding Personal Information
Changing or deleting your personal data
You may review, update, correct, or delete personal information you have furnished by contacting us at privacy@retokenscapital.com or, in certain cases, by accessing your account. For your protection, we may only act on requests from the email address associated with your account, and we may need to verify your identity. We will try to comply with such requests in a reasonably timely manner, subject to our recordkeeping obligations as a broker-dealer, which may require us to retain certain information.
Data retention
We retain personal information for as long as you use any of our Site or Services, or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements, and comply with applicable laws, including books-and-records requirements applicable to broker-dealers. We may retain information in anonymized and aggregated form, or in archived or backup copies, as required by law.
Download or access personal information
You can ask us for a copy of your personal information, including in machine-readable form, by emailing privacy@retokenscapital.com.
Opting out of email communications
We may use some information we collect for marketing, including to send promotional communications. To stop receiving these, follow the opt-out instructions (such as “Unsubscribe”) in those communications, or contact us at privacy@retokenscapital.com. Despite your preferences, we may send service-related communications, including notices of updates to our Terms of Service or this Privacy Policy and communications required by law or regarding your account, security, or transactions.
Opting out of sharing with affiliated and non-affiliated third parties for marketing
If you would like to opt out of sharing your information with Affiliates and non-affiliated third parties for marketing or solicitation purposes, please contact us at privacy@retokenscapital.com. See also the Regulation S-P / GLBA notice above.
Our Use of Tracking Technologies
We may use cookies, pixel tags, and other technologies on our Site or as part of our Services to collect information automatically or passively. A “cookie” is a small amount of data sent to your browser and stored on your device that can be used to provide a tailored experience and recognize you on a return visit. Cookies must be enabled if you wish to access certain personalized features. You may set your browser to refuse cookies; helpful information is available at allaboutcookies.org/manage-cookies. Unless you adjust your settings, our system will send cookies when you access our Site or Services, and by using the Site you consent to our use of cookies. We may also use pixel tags (web beacons) to understand which parts of our Site are visited and whether email messages are opened.
Additional Privacy-Related Information
Links to third-party websites
We may provide links to third-party websites. We have no control over those websites, which may be subject to their own terms and privacy policies. We do not endorse and are not responsible for their content, and you agree we will not be liable for any damage or loss caused by your use of or reliance on those websites.
How we respond to “Do Not Track” signals
Your browser settings may allow you to transmit a “Do Not Track” signal. To learn more, visit allaboutdnt.com. If you access our Site from a mobile device, we may collect mobile advertising identifiers; you may be able to opt out through your device settings, subject to the offerings of the operating-system provider.
California privacy
This section provides information to California residents whose personal information is processed pursuant to the California Consumer Privacy Act (“CCPA”), as amended. It does not apply to personal information that is collected, processed, sold, or disclosed pursuant to federal financial privacy laws (such as the GLBA and Regulation S-P), which is exempt from the CCPA. For information we collect and how we use it, California residents should refer to the sections above. As a California resident, you may have certain rights regarding personal information that is not exempt, subject to the CCPA's exceptions. To make a request, contact privacy@retokenscapital.com.
Users outside the United States
The Company is based in the United States. Our Site and Services are controlled and operated from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your personal information may be stored and processed in any country where we or our service providers have facilities, and by using the Site or Services you consent to the transfer of information to countries outside your country of residence, including the United States.
Children's policy
Our Site and Services are not intended for children under the age of 18. We do not knowingly solicit data from, or market to, children under 18. If a parent or guardian becomes aware that their child has provided us information, they should contact us at privacy@retokenscapital.com, and we will take steps to delete such information within a reasonable time.
Contact Us
Please contact us at privacy@retokenscapital.com if you have questions about this Privacy Policy, your personal information, or our Site or Services. You may also write to us at: REtokens Capital LLC, 12904 E Nora, Suite C, Spokane Valley, WA 99216. You may verify the Company's broker-dealer registration on FINRA BrokerCheck.
