Privacy Policy

Effective date: August 1, 2024

Iroquois Valley Farmland REIT (the “Company”, “us”, “we”, or “our”) operates the https://iroquoisvalley.com/ website and the investor portal available at Investor Cafe (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. Our Privacy Policy for Iroquois Valley Farmland REIT is based on the Free Privacy Policy template.

By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

PERSONAL DATA

We collect personal data that you provide us when you create an account, inquire about us or our services, or when you otherwise contact us. Personal data includes your name, mailing address, telephone number, e-mail address, billing address, tax identification number (i.e. EIN or SSN), payment information, financial institution information, information about uploads, Internet Protocol (IP) address and the device used to upload the Materials (this data may be meta-data embedded in the Materials) and other information relating to uploaded Materials or that may be used to identify, contact, or locate you (“Personal Data”). For purposes of this Privacy Policy, “Materials” means all audio and visual works or content in any medium or format, including film, video, text, logos, artwork, graphics, pictures, images, advertisements, aural and other forms of expression, whether in still, live, animated or streaming format, contained in works posted, uploaded or provided to the Company, the Service, or into the technologies described herein, in any method or form, by you, or by anyone else on your behalf.

USAGE DATA

We may also automatically collect information regarding how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, language preferences, referring URLs, country, device name, operating system, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. Like many businesses we also collect information through cookies and similar technologies, which is described in more detail below.

How We Collect Data

Registration

Prior to your using the Service, you may be required to provide certain Personal Data to create an account (“Account”) to access or enable features or functionality of the Service. Failure to provide all information required during registration may prevent access to any or all of the Service, and failure to maintain accurate information may result in suspension or termination of access to all or some of the Service.

Uploading and Downloading Materials

If you use the Service and you upload or post Materials to or download Materials from the Service, the Materials may include meta-data or be transmitted with data, such as the type of device through which the Materials were created, the device’s IP address, the domain name of your internet service provider and other such data. This data may necessarily be provided to and collected by the Company when Materials are uploaded, posted to or downloaded from the Service.

Information Collected Through Technology

While you are able to visit certain portions of the Service anonymously, the Company or its third-party service providers may still collect Personal Data and other information about your use of the Service (e.g., your Internet browser, operating system, IP address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:

Cookies and Web Beacons

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies: We use Session Cookies to operate our Service.
• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• Security Cookies: We use Security Cookies for security purposes.

IP Address

You may visit areas of the Service anonymously without the need to register an Account. Even in such cases, the Company may collect IP addresses automatically. An IP address is a number that is automatically assigned to your computer or device whenever you begin services with an internet service provider. Each time you access the Service and each time you request one of the Company’s pages, the server logs the IP address.

Web Beacons

Web beacons are small pieces of data that are embedded in web pages and e-mails. The Company may use these technical methods in HTML e-mails that the Company sends to you to determine whether you have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that is Personal Data.

Tracking Materials Usage

If you use the Services and you upload or post Materials to, or download Materials from, the Service or to or from a third-party website, the Company tracks and captures Personal Data and other information associated with registered Accounts and the use of Materials.

Use of Data

We use the collected data for various purposes:

• To provide and maintain the Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer care and support
• To provide analysis or valuable information so that we can improve the Service
• To monitor the usage of the Service
• To detect, prevent and address technical issues
• If you have registered for an Account, we may use your Personal Data:
  • to make payments to you,
  • receive payments from you, and
  • to prepare and send or make available tax information
• For other purposes with your consent

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Disclosure Of Data

Selling

We do not sell your Personal Data.

Legal Requirements

We may disclose your information in the good faith belief that such action is necessary:

• To comply with a legal obligation
• To protect and defend the rights or property of Iroquois Valley Farmland REIT and its affiliates
• To prevent or investigate possible wrongdoing
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. For example, we use Google Forms to enable you to provide certain information to us and FTI Consulting for our investor platform.

These third parties have access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Business Purposes

BUSINESS TRANSFERS

We may share or transfer your information with, or during negotiations of, any merger, sale of the company assets, financing, or acquisition of all or a portion of our business or company to another company.

AFFILIATES

We may share your information with our affiliates, in which case we will require those affiliates to respect and comply with this Privacy Policy. Affiliates include our subsidiaries, joint venture partners, and other companies that we control or that are under common control with us.

BUSINESS PARTNERS

We may share your information with certain business partners to offer you certain products, services, or promotions.

Security Of Data

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected information from children without verification of parental consent, we take steps to remove that information from our servers.

Review, Update, or Delete Your Data

Based on the applicable laws of your state or country, you may have the right to request access to personal information we collect from you, change that information or request that it be deleted. To make any such request please email us at info@iroquoisvalleyfarms.com.

California Privacy Rights – California Consumer Privacy Act (CCPA)

The CCPA provides California residents with specific rights regarding their personal information. Each right includes the ability to make a specific consumer request and corresponding obligation of the receiving party to (i) verify the identity of the requestor and (ii) respond in accordance with CCPA guidelines. This section describes your CCPA rights and explains how to exercise those rights.

Right to Request Information Regarding Personal Information Use/Disclosure and Portability

You have the right to request a summary of the collection, use, and disclosure of your personal information over the past 12 months. In response to a verifiable request for these services, we will disclose the following information for the Service:

• The categories, specific types, and sources of personal information we collected about you.
• Our business purpose for collecting the personal information.
• The categories of third parties with whom we share that personal information and the purpose for the disclosure.

You also have the right to request a copy of this personal information in a readily useable format that is transferable to other entities (frequently referred to as “data portability”). If you make a data portability request, the Company may be (i) restricted from providing certain sensitive personal information in response to the request or (ii) prohibited from granting the request entirely if it presents an unreasonable security risk.

Right to Request Deletion of Personal Information

You have the right to request that the Company delete any of your personal information that we collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete or de-identify (and direct our service providers to delete or de-identify) your personal information from our records, unless one of the following exceptions applies:

• Complete the transaction for which we collected the personal information, provide the Service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug the Service to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Submitting CCPA Requests – Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us by either:

• Calling us toll-free at: (847) 859-6645 ext. 1, OR
• Sending an email to invest@iroquoisvalleyfarms.com

Only you (or someone legally authorized to act on your behalf) may make a verifiable request related to your personal information. You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:

• Provide sufficient information that allows us to confirm your identity as the person about whom we collected personal information (and, if applicable, the authority and identity of an authorized representative).
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note, we cannot respond to your request or provide you with personal information if we cannot (i) verify your identity or authority to make the request and (ii) confirm the personal information relates to you. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

CCPA Request Responses and Timelines

We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require additional time beyond the 45 days, we are entitled to an extension up to an additional 45 days (for a total response timeline capped at 90 days). If an extension is necessary, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account where possible. If you do not have an account with us, or your existing account lacks a communication feature, we will deliver our written response to your designated email address.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales – Opt Out Rights

The Company does not sell personal information collected through the Service, and no such activity has occurred in the prior 12 months. If the Company changes its practices and engages in the sale of information, we will provide advance notification to impacted individuals and offer the ability to opt in/opt out in accordance with CCPA requirements.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Shine the Light Requests

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the address listed in the section titled “Submitting CCPA Requests – Exercising Access, Data Portability, and Deletion Rights.”

California Online Privacy Protection Act (“CalOPPA”)

The Company does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may have features that allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: info@iroquoisvalleyfarms.com