Privacy Policy

Introduction

Aspen Exchange (“Aspen Exchange,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the information you provide to us. This Privacy Policy describes the types of information we may collect from you, or that you may provide, when you visit aspen1031.com (the “Site”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information we collect:

• On the Site, including through contact forms, exchange inquiry forms, resource forms, and other online forms;
• In email, text message, telephone, or other electronic communications sent through or in connection with the Site;
• When you interact with our advertising, analytics, or other applications on third-party websites and services, where applicable; and
• Through other communications or interactions related to our services.

This policy does not apply to information collected by third parties through applications, websites, services, or content that may link to or be accessible from the Site, except as otherwise expressly described in this Privacy Policy.

Please read this Privacy Policy carefully. By accessing or using the Site, you acknowledge the practices described in this Privacy Policy. If you do not agree with these practices, you should discontinue use of the Site.

Information We Collect

We may collect several types of information from and about users of the Site, including:

• Information by which you may be personally identified, such as your name, mailing address, email address, telephone number, or other contact information;
• Information about you that does not individually identify you, such as aggregated or statistical information; and
• Information about your internet connection, device, browser, and usage of the Site.

We may collect this information directly from you, automatically as you navigate through the Site, and, where applicable, from third-party sources such as service providers, analytics providers, advertising partners, and business partners.

Information You Provide to Us

Information you provide to us through or in connection with the Site may include:

• Contact information, such as your name, mailing address, email address, and telephone number;
• Exchange-related information, such as information about a property you may be selling or acquiring, property type, transaction timing, exchange objectives, and other information you voluntarily provide regarding a potential or existing 1031 exchange;
• Financial or transaction information, where voluntarily provided in connection with an exchange inquiry or transaction;
• Communications, including messages submitted through contact forms, email, telephone, text message, or other communication channels;
• Documents and attachments you choose to submit or upload;
• Professional information, such as your company, role, real estate brokerage, title or escrow company, or professional advisor information; and
• Records of consent, such as the date, time, and method by which you provided consent to receive communications.

You should provide only information reasonably necessary for your inquiry or exchange and should avoid submitting unnecessary sensitive personal information through general website forms.

Information Collected Automatically

As you navigate the Site, we and third-party service providers acting on our behalf may use automatic data collection technologies to collect information about your device, browsing actions, and patterns.

This information may include:

• Details of your visits to the Site, including traffic data, referring and exit pages, and other communication data;
• Information about your device and internet connection, including IP address, approximate geographic location derived from your IP address, device identifiers, operating system, and browser type and version;
• Pages you view, links you click, time spent on pages, and interactions with Site content and forms; and
• Information collected through cookies, pixels, web beacons, tags, and similar technologies, as described in our Cookie Policy.

Information from Third Parties

We may receive information about you from third-party sources, such as:

• Analytics providers;
• Advertising and marketing partners;
• Business partners;
• Real estate professionals;
• Title and escrow companies;
• Technology and service providers; and
• Other parties where you have authorized or directed the sharing of information.

Information received from third parties may be used to supplement information you provide, facilitate communications, understand website activity, support exchange-related services, or improve our marketing and website operations.

How We Use Your Information

We may use information that we collect about you or that you provide to us for purposes including:

• Responding to inquiries regarding 1031 exchanges and our services;
• Communicating with you regarding a potential or existing exchange;
• Providing information, resources, and services you request;
• Facilitating communications relating to an exchange transaction;
• Coordinating, where applicable, with parties involved in an exchange transaction, such as title and escrow companies and professional advisors;
• Providing and maintaining the Site;
• Improving Site functionality, content, usability, accessibility, and performance;
• Understanding Site usage and visitor trends;
• Measuring advertising and marketing effectiveness;
• Maintaining records and administering business operations;
• Detecting, preventing, and addressing fraud, unauthorized activity, security incidents, and technical issues;
• Complying with applicable laws, regulations, legal processes, and governmental requests;
• Protecting our rights, property, and the security of our Site and users; and
• Performing other purposes disclosed to you at the time information is collected or with your consent.

We may also create aggregated or de-identified information that does not reasonably identify you for analytics, reporting, research, and business purposes.

How We Share Your Information

We may disclose information we collect as described in this Privacy Policy in the following circumstances:

• Service providers and vendors: We may share information with vendors and service providers that perform services on our behalf, including website hosting, analytics, customer relationship management, communications, form processing, security, document management, and technology services.
• Exchange-related parties: Where appropriate and necessary to facilitate an exchange, we may share information with parties involved in the transaction, such as title companies, escrow companies, real estate professionals, attorneys, accountants, tax advisors, financial advisors, or other professionals at your direction or as necessary to provide requested services.
• Marketing and analytics providers: We may share certain information, including cookie identifiers and usage information, with analytics and advertising providers as described in our Cookie Policy and subject to applicable law.
• Business transfers: If Aspen Exchange is involved in a merger, acquisition, reorganization, financing, sale of assets, bankruptcy, or similar transaction, information may be transferred as part of that transaction.
• Legal requirements: We may disclose information when required to comply with applicable law, court order, subpoena, legal process, or lawful governmental request.
• Protection of rights: We may disclose information when reasonably necessary to enforce our agreements, protect our rights or property, investigate potential violations, or protect the safety and security of Aspen Exchange, our users, or others.
• With your consent: We may disclose information for other purposes with your consent or at your direction.

We do not sell your personal information to third parties for monetary consideration in the conventional retail sense. To the extent applicable privacy laws define “sale” or “sharing” more broadly, including certain disclosures associated with cross-context behavioral advertising, applicable rights and choices are described below.

Cookies & Tracking Technologies

We use cookies and similar tracking technologies to operate and improve the Site, remember preferences, understand website usage, measure marketing performance, and support certain website functionality.

For additional information about cookies, tracking technologies, their purposes, and available choices, please review our separate Cookie Policy.

Communications & Text Messaging

If you provide your telephone number and consent to receive communications from Aspen Exchange, we may use that information to communicate with you regarding your inquiry, exchange, requested information, or services.

Message frequency may vary. Message and data rates may apply depending on your mobile carrier and plan.

You may opt out of text messages at any time by replying STOP to a message, where supported, or by contacting us using the information below.

Consent to receive text messages is not a condition of purchasing services.

We do not sell mobile opt-in information or text messaging consent information to third parties for their own marketing purposes.

Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, provide requested services, maintain appropriate business and transaction records, resolve disputes, comply with legal and regulatory obligations, and protect our rights.

The length of time we retain information depends on factors including:

• The nature and purpose of the information;
• Whether we have an ongoing relationship with you;
• Whether the information relates to an exchange or transaction;
• Applicable legal, tax, accounting, regulatory, or recordkeeping requirements; and
• Whether retention is reasonably necessary for legal claims, investigations, disputes, or enforcement purposes.

When personal information is no longer reasonably necessary for the purposes described in this Privacy Policy, we may securely delete, destroy, anonymize, or otherwise dispose of it in accordance with applicable requirements and our internal procedures.

Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against accidental loss and unauthorized access, use, alteration, or disclosure.

These measures may include:

• Encryption of data in transit using TLS/SSL technologies;
• Access controls designed to limit access to personal information;
• Monitoring of systems for potential security vulnerabilities and incidents;
• Security measures designed to protect online forms and submitted information; and
• Contractual or other safeguards applicable to service providers that process information on our behalf.

No transmission of information over the internet or electronic storage system can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect information, we cannot guarantee absolute security.

Your Privacy Rights

Depending on where you live and applicable law, you may have certain rights regarding your personal information, which may include the right to:

• Request confirmation of whether we process your personal information;
• Request access to personal information we maintain about you;
• Request correction of inaccurate personal information;
• Request deletion of personal information, subject to applicable exceptions;
• Request a portable copy of certain personal information;
• Opt out of certain uses or disclosures of personal information, including targeted advertising where applicable;
• Withdraw consent where processing is based on consent; and
• Submit a complaint to an applicable privacy regulator or supervisory authority.

To exercise applicable privacy rights, contact us using the information in the Contact Information section below. We may need to verify your identity before completing certain requests, as permitted or required by law.

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), may provide you with certain rights concerning your personal information.

Depending on the circumstances, these rights may include:

• Right to Know: The right to request information about the categories and specific pieces of personal information collected, the sources of that information, the purposes for collection, and categories of third parties with whom information is disclosed.
• Right to Delete: The right to request deletion of personal information, subject to exceptions permitted by law.
• Right to Correct: The right to request correction of inaccurate personal information.
• Right to Opt Out of Sale or Sharing: The right to opt out of certain activities that constitute a “sale” or “sharing” under applicable California privacy law.
• Right to Limit: Where applicable, the right to limit certain uses of sensitive personal information.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising applicable privacy rights.

To submit a privacy request, contact us at letstalk@aspen1031.com or 424-239-7388.

Where required by law, we will process and respond to verifiable requests within the applicable statutory timeframe.

Other State Privacy Laws

Residents of other states may have privacy rights under applicable state privacy laws. Depending on your state of residence and the circumstances of our processing activities, these rights may include rights to access, correct, delete, obtain a portable copy of personal information, or opt out of certain processing activities.

To exercise applicable rights, contact us using the information below. We will evaluate and respond to requests consistent with applicable law.

Children’s Privacy

The Site is not intended for children under the age of 18, and we do not knowingly collect personal information from children under 18.

If you believe a child under 18 has provided personal information through the Site, please contact us. We will take reasonable steps to investigate and, where appropriate, delete the information in accordance with applicable law.

International Visitors

The Site is intended primarily for visitors in the United States. If you access the Site from outside the United States, you do so on your own initiative and are responsible for compliance with applicable local laws to the extent they apply.

Information submitted through the Site may be transferred to, stored in, or processed in the United States, where privacy laws may differ from those in your jurisdiction.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, technology, legal requirements, or other operational considerations.

When changes are made, we will update the “Last Updated” or effective date displayed on this page. Where appropriate, we may provide additional notice of material changes.

We encourage you to periodically review this Privacy Policy to remain informed about how we collect, use, and protect information.

Contact Information

If you have questions about this Privacy Policy, wish to exercise applicable privacy rights, or have a privacy-related concern, please contact us:

Aspen Exchange
Website: aspen1031.com
Phone: 424-239-7388
Email: letstalk@aspen1031.com