It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, ponzi schemes, cybercrime and other investment-related fraudulent activity. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex. Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.
The firm has designated Aline Gialluisi Seripieri de Abreu as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML program. Aline Gialluisi Seripieri de Abreu has a working knowledge of the BSA and its implementing regulations and is qualified by experience, knowledge and training, including bachelor’s degree in business administration with over 15 years of experience in finance and customer credit assessment. The duties of the AML Compliance Person will include monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees. The AML Compliance Person will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Suspicious Activity Reports (SARs) are filed with the Financial Crimes Enforcement Network (FinCEN) when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce the firm’s AML program.
We will respond to a Financial Crimes Enforcement Network (FinCEN) request concerning accounts and transactions (a 314(a) Request) by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity or organization named in the 314(a) Request as outlined in the Frequently Asked Questions (FAQ) located on FinCEN’s secure website. We understand that we have 14 days (unless otherwise specified by FinCEN) from the transmission date of the request to respond to a 314(a) Request. Unless otherwise stated in the 314(a) Request or specified by FinCEN, we are required to search those documents outlined in FinCEN’s FAQ. If we find a match, Aline Gialluisi Seripieri de Abreu will report it to FinCEN via FinCEN’s Web-based 314(a) Secure Information Sharing System within 14 days or within the time requested by FinCEN in the request. If the search parameters differ from those mentioned above (for example, if FinCEN limits the search to a geographic location), Aline Gialluisi Seripieri de Abreu will structure our search accordingly. If Aline Gialluisi Seripieri de Abreu searches our records and does not find a matching account or transaction, then Aline Gialluisi Seripieri de Abreu will not reply to the 314(a) Request. We will maintain documentation that we have performed the required search for 3 years. We will not disclose the fact that FinCEN has requested or obtained information from us, except to the extent necessary to comply with the information request. Aline Gialluisi Seripieri de Abreu will review, maintain and implement procedures to protect the security and confidentiality of requests from FinCEN similar to those procedures established to satisfy the requirements of Section 501 of the Gramm-Leach-Bliley Act with regard to the protection of customers’ nonpublic information. We will direct any questions we have about the 314(a) Request to the requesting federal law enforcement agency as designated in the request. Unless otherwise stated in the 314(a) Request, we will not be required to treat the information request as continuing in nature, and we will not be required to treat the periodic 314(a) Requests as a government provided list of suspected terrorists for purposes of the customer identification and verification requirements.
We understand that the receipt of a National Security Letter (NSL) is highly confidential. We understand that none of our officers, employees or agents may directly or indirectly disclose to any person that the FBI or other federal government authority has sought or obtained access to any of our records. To maintain the confidentiality of any NSL we receive, we will process and maintain the NSL at a safety file cabinet. If we file a SAR after receiving an NSL, the SAR will not contain any reference to the receipt or existence of the NSL. The SAR will only contain detailed information about the facts and circumstances of the detected suspicious activity.
We understand that the receipt of a grand jury subpoena concerning a customer does not in itself require that we file a Suspicious Activity Report (SAR). When we receive a grand jury subpoena, we will conduct a risk assessment of the customer subject to the subpoena as well as review the customer’s account activity. If we uncover suspicious activity during our risk assessment and review, we will elevate that customer’s risk assessment and file a SAR in accordance with the SAR filing requirements. We understand that none of our officers, employees or agents may directly or indirectly disclose to the person who is the subject of the subpoena its existence, its contents or the information we used to respond to it. To maintain the confidentiality of any grand jury subpoena we receive, we will process and maintain the subpoena in a safe box. If we file a SAR after receiving a grand jury subpoena, the SAR will not contain any reference to the receipt or existence of the subpoena. The SAR will only contain detailed information about the facts and circumstances of the detected suspicious activity.
We will share information with other financial institutions regarding individuals, entities, organizations and countries for purposes of identifying and, where appropriate, reporting activities that we suspect may involve possible terrorist activity or money laundering. Aline Gialluisi Seripieri de Abreu will ensure that the firm files with FinCEN an initial notice before any sharing occurs and annual notices thereafter. We will use the notice form found at FinCEN’s website. Before we share information with another financial institution, we will take reasonable steps to verify that the other financial institution has submitted the requisite notice to FinCEN, either by obtaining confirmation from the financial institution or by consulting a list of such financial institutions that FinCEN will make available. We understand that this requirement applies even to financial institutions with which we are affiliated, and that we will obtain the requisite notices from affiliates and follow all required procedures. We will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, for example, by segregating it from the firm’s other books and records. We also will employ procedures to ensure that any information received from another financial institution shall not be used for any purpose other than: • identifying and, where appropriate, reporting on money laundering or terrorist activities; • determining whether to establish or maintain an account, or to engage in a transaction; or • assisting the financial institution in complying with performing such activities.
Before opening an account, and on an ongoing basis, Aline Gialluisi Seripieri de Abreu will check to ensure that a customer does not appear on the SDN list or is not engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC. If we determine that a customer is on the SDN list or is engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC, we will reject the transaction and/or block the customer’s assets and file a blocked assets and/or rejected transaction form with OFAC within 10 days. We will also call the OFAC Hotline at (800) 540-6322 immediately. Our review will include customer accounts, transactions involving customers (including activity that passes through the firm such as wires) and the review of customer transactions that involve physical security certificates or application-based investments (e.g., mutual funds).
In addition to the information we must collect under FINRA Rules 2090 (Know Your Customer) and 2111 (Suitability) and the 4510 Series (Books and Records Requirements), and Securities Exchange Act of 1934 (Exchange Act) Rules 17a-3(a)(9) (Beneficial Ownership regarding Cash and Margin Accounts), 17a-3(a)(17) (Customer Accounts) and Regulation Best Interest, we have established, documented and maintained a written Customer Identification Program (CIP). We will collect certain minimum customer identification information from each customer who opens an account; utilize risk-based measures to verify the identity of each customer who opens an account; record customer identification information and the verification methods and results; provide the required adequate CIP notice to customers that we will seek identification information to verify their identities; and compare customer identification information with government-provided lists of suspected terrorists, once such lists have been issued by the government.
Prior to opening an account opening officer will collect the following information for all accounts, if applicable, for any person, entity or organization that is opening a new account and whose name is on the account: (1) the name; (2) date of birth (for an individual); (3) an address, which will be a residential or business street address (for an individual), an Army Post Office (APO) or Fleet Post Office (FPO) box number, or residential or business street address of next of kin or another contact individual (for an individual who does not have a residential or business street address), or a principal place of business, local office, or other physical location (for a person other than an individual); and (4) an identification number, which will be a taxpayer identification number (for U.S. persons), or one or more of the following: a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard (for non-U.S. persons). In the event that a customer has applied for, but has not received, a taxpayer identification number, we will request a filling receipt copy to confirm that the application was filed before the customer opens the account and to obtain the taxpayer identification number within a reasonable period of time after the account is opened. When opening an account for a foreign business or enterprise that does not have an identification number, we will request alternative government-issued documentation certifying the existence of the business or enterprise.
If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our firm will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, our AML Compliance Person will be notified so that we can determine whether we should report the situation to FinCEN on a SAR.
Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers. Aline Gialluisi Seripieri de Abreu will analyze the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer. We will verify customer identity through documentary means, non-documentary means or both. We will use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever necessary. We may also use non-documentary means, if we are still uncertain about whether we know the true identity of the customer. In verifying the information, we will consider whether the identifying information that we receive, such as the customer’s name, street address, zip code, telephone number (if provided), date of birth and Social Security number, allow us to determine that we have a reasonable belief that we know the true identity of the customer . Appropriate documents for verifying the identity of customers include the following: • For an individual, an unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport; and • For a person other than an individual, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement or a trust instrument. We understand that we are not required to take steps to determine whether the document that the customer has provided to us for identity verification has been validly issued and that we may rely on a government-issued identification as verification of a customer’s identity. If, however, we note that the document shows some obvious form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the customer’s true identity. We will use the following non-documentary methods of verifying identity: • Independently verifying the customer’s identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database or other source • Checking references with other financial institutions; or • Obtaining a financial statement. We will use non-documentary methods of verification when: (1) the customer is unable to present an unexpired government-issued identification document with a photograph or other similar safeguard; (2) the firm is unfamiliar with the documents the customer presents for identification verification; (3) the customer and firm do not have face-to-face contact; and (4) there are other circumstances that increase the risk that the firm will be unable to verify the true identity of the customer through documentary means. We will verify the information within a reasonable time before or after the account is opened. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information, or in some instances when we need more time, we may, pending verification, restrict the types of transactions or dollar amount of transactions. If we find suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we will, after internal consultation with the firm’s AML Compliance Person, file a SAR in accordance with applicable laws and regulations. We recognize that the risk that we may not know the customer’s true identity may be heightened for certain types of accounts, such as an account opened in the name of a corporation, partnership or trust that is created or conducts substantial business in a jurisdiction that has been designated by the U.S. as a primary money laundering jurisdiction, a terrorist concern, or has been designated as a non-cooperative country or territory. We will identify customers that pose a heightened risk of not being properly identified. We will also take the following additional measures that may be used to obtain information about the identity of the individuals associated with the customer when standard documentary methods prove to be insufficient.
When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (1) not open an account; (2) impose terms under which a customer may conduct transactions while we attempt to verify the customer’s identity; (3) close an account after attempts to verify a customer’s identity fail; and (4) determine whether it is necessary to file a SAR in accordance with applicable laws and regulations.
We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain documents that describe the methods and the results of any measures we took to verify the identity of a customer. We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer’s identity for five years after the record is made.
At such time as we receive notice that a federal government agency has issued a list of known or suspected terrorists and identified the list as a list for CIP purposes, we will, within a reasonable period of time after an account is opened (or earlier, if required by another federal law or regulation or federal directive issued in connection with an applicable list), determine whether a customer appears on any such list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by Treasury in consultation with the federal functional regulators. We will follow all federal directives issued in connection with such lists. We will continue to comply separately with OFAC rules prohibiting transactions with certain foreign countries or their nationals.
We will provide notice to customers that the firm is requesting information from them to verify their identities, as required by federal law. We will use the following method to provide notice to customers: Important Information About Procedures for Opening a New Account To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.
We may, under the following circumstances, rely on the performance by another financial institution (including an affiliate) of some or all of the elements of our CIP with respect to any customer that is opening an account or has established an account or similar business relationship with the other financial institution to provide or engage in services, dealings or other financial transactions: • when such reliance is reasonable under the circumstances; • when the other financial institution is subject to a rule implementing the anti-money laundering compliance program requirements of 31 U.S.C. § 5318(h), and is regulated by a federal functional regulator; and • when the other financial institution has entered into a contract with our firm requiring it to certify annually to us that it has implemented its anti-money laundering program and that it will perform (or its agent will perform) specified requirements of the customer identification program.
In addition to the information collected under the written Customer Identification Program, FINRA Rules 2090 (Know Your Customer) and 2111 (Suitability) and the 4510 Series (Books and Records Requirements), and Securities Exchange Act of 1934 (Exchange Act) Rules 17a-3(a)(9) (Beneficial Ownership regarding Cash and Margin Accounts), 17a-3(a)(17) (Customer Accounts) and Regulation Best Interest, we have established, documented and maintained written policies and procedures reasonably designed to identify and verify beneficial owners of legal entity customers and comply with other aspects of the Customer Due Diligence (CDD) Rule. We will collect certain minimum CDD information from beneficial owners of legal entity customers. We will understand the nature and purpose of customer relationships for the purpose of developing a customer risk profile. We will conduct ongoing monitoring to identify and report suspicious transactions, and, on a risk basis, maintain and update customer information.
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Disclamer Important Notices & Disclaimer / Risk of Loss The information contained herein has been prepared to assist interested parties in making an evaluation of the potential investment and does not purport to contain all the information that an interested party may need or desire. The information about the potential investment will be fully set forth in the different definitive documents relating thereto, including the Operating Agreement(s) of the relevant investment vehicles(s), and the subscription documents, which will be made available prior to the funding of the proposed investment. In the case of any inconsistency between the descriptions or terms in this Memorandum and the definitive documents, the definitive documents shall control. Interested parties should conduct their own independent investigation and analysis of the opportunity and of the data set forth in this Memorandum. 2bTrust does not assume any responsibility for the completeness or accuracy of any of the information sourced from third-parties and set forth herein. This Memorandum contains “forward-looking statements” within the securities laws of certain jurisdictions, including the United States. In some cases, these forward-looking statements can be identified by the use of forward-looking terminology, including the words “preliminary”, “believes”, “estimates”, “anticipates”, “expects”, “may”, “will”, “plans”, “continue”, “ongoing”, “potential”, “predict”, “project”, “target”, “seek” or “should” or, in each case, their negative or other variations or comparable terminology or by discussions of plans, objectives, targets, future events or intentions. By their nature, forward-looking statements involve known and unknown risks, uncertainties and other factors because they relate to events and depend on circumstances that may or may not occur in the future and which are outside of 2bTrust s control. 2bTrust cautions you that forward-looking statements are not guarantees of future performance of the investment opportunity discussed herein, and 2bTrust makes no representation or warranty as to the 2bTrust accuracy, materiality or completeness of the Memorandum or the information contained in, or omitted from, the Memorandum or any other written or oral communications transmitted to the recipient during its evaluation of the proposed investment. Furthermore, the information provided relates only to the periods and at the times noted herein. 2bTrust has no obligation to update the information contained herein. This is not an offer to sell or distribute any product or service. No assurance can be given that the investment objectives with respect to the transaction will be achieved or that investors will receive a return of their capital. This Memorandum has been prepared for the exclusive use of the party to whom it is delivered (such party, together with its subsidiaries and affiliates, the “Recipient”). Although 2bTrust believes the information is accurate in all material respects, 2bTrust does not make any representation or warranty, either express or implied, as to the accuracy, completeness or reliability of the information contained in this Memorandum. Any estimates or projections contained in this presentation are based upon the reasonable judgment of 2bTrust. Nothing contained herein is, or shall be relied upon as, a promise or representation as to the past or future. 2bTrust expressly disclaims any and all liability relating to or resulting from the use of this Memorandum. In addition, the information contained in this Memorandum is as of the date hereof unless otherwise expressly stated, and 2bTrust has no obligation to update such information, including in the event that such information becomes inaccurate. Any investment should be first made in consultation with your financial, tax and other professional advisors. It should not be assumed that any of the transactions, securities, holdings or sectors discussed were or will prove to be profitable, or that the recommendations or decisions 2bTrust makes in the future will be profitable. Investments like the one described in this Memorandum involves the risk of loss, including the total loss of your investment. The due diligence, legal documentation, and legal structuring process is ongoing for the transaction discussed herein. Hence, the information presented in the Memorandum is preliminary. The content of this Memorandum represents views expressed by 2bTrust based on assumptions that 2bTrust believes to be reasonable, but there are no assurances that many factors could occur that result, with the benefit of hindsight, the statements and views expressed herein to be inaccurate, and such differences could be material. The Recipient confirms that it is not relying on the information contained herein to make any decision. The Memorandum does not purport to be all-inclusive or to contain all of the information that the Recipient may require. Each participant will be required to represent and warrant, among other things, that it is a knowledgeable investor and that it has done an independent investigation, including review of all documents related to the investment, that it deems necessary to review prior to the making of the investment. Accordingly, any prospective investor should review all documentation provided by 2bTrust carefully and should consult with their own advisors. All communications, inquiries and requests for additional information should be directed by email to ir@2btrust.com or by phone to +1-407-735 1228.
GDPR The General Data Protection Regulation (GDPR) Further rights for persons or information covered by GDPR With respect to EEA residents and where your Personal Information is processed by an Entity established in the EEA (“Covered Individuals”), you have a number of legal rights under GDPR in relation to the Personal Information that we hold about you. These rights include: Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information, (in particular, information that is subject to legal professional privilege); Requesting that we correct your personal information if it is inaccurate or incomplete; Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it; Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request; Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so. We have designated a Data Protection Officer (“DPO”) to enhance and promote compliance with and understanding of privacy and data protection principles. If you wish to do any of the above, please send an email to contact@2btrust.com. We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data and for any additional copies of the Personal Information you request from us. We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request. Updates to this Privacy Policy This Privacy Policy was last updated on 20 Nov 2020. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website. How to contact us We welcome your views about our website and our Privacy Policy. If you have any questions about this Policy, please contact the Data Protection Office at contact@2btrust.com or please contact 2b Customer Service through the 2bTrust website at 2btrust.com/help. How long do we retain your Personal Information? We retain your Personal Information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings.
Privacy Policy Legal Disclaimer Effective Date: November 01, 2020 THIS PRIVACY POLICY APPLIES TO OUR WEBSITES AND PLATFORMS. This Policy describes how 2bTrust LLC and its affiliates (“2bTrust LLC”, “We”, “we”, or “us”) treats personal information collected on the websites and platforms where this policy is located (each a “Site”). This policy does not apply to information 2bTrust LLC collects offline, through email, or through other sites. This policy also does not apply to websites or platforms where it is not posted and where a link to the privacy policy is not provided. It also may not apply to the practices of all other 2bTrust LLC subsidiaries or other affiliates. For example, this policy does not apply to customers or consumers of 2bTrust LLC services or products with respect to your use of such services or products. WE COLLECT INFORMATION FROM AND ABOUT YOU. We collect contact information. For example, we might collect your name, address, and email address when you register on our Site or apply for a job. We collect information you submit or post. We collect information when you contact us. We may also collect information you submit through our Site, for example when applying for a job or submitting your resume. We collect other information. We may collect usage data on how you use our Site. This may include information about your browser. We may also collect information about your use of our Site and how long you visited our Site. WE COLLECT INFORMATION IN DIFFERENT WAYS. We collect information directly from you. For example, if you register with us or apply for a job. We collect information from you passively. We use tracking tools like browser cookies and web beacons. A cookie and a web beacon are pieces of data stored on your device containing information about your visit. You consent to any such use. Learn more about these tools and how you can control them, here. Third party analytics services may use cookies and web beacons through our Site to provide us with information about how you use and interact with our Site. We use Google Analytics to collect information about how visitors use our website. For example, we collect details of the Site where a visitor has come from and the total number of times a visitor has been to our website. We get information about you from third parties. For example, our business partners or vendors may give us information about you. We may combine this information with information you give us. We collect information as otherwise described at the time of collection. WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE. We use information to respond to your requests or questions. For example, we might use your information to contact you about employment opportunities. We use information to improve our website and the information we provide. We might use your information to customize your experience with us. For example, we may use your information to improve our website and our recruiting efforts. We use information for security purposes. We may use information to enforce our rights, protect our company, affiliates, our customers, or our website, or a third-party website or platform. We use information to inform you about the company. For example, we might send you information about our company and what we offer. We might tell you about new features or updates. We may also use your information to send you information about career opportunities. We use information to communicate with you about your account or our relationship. We may contact you about your use of our website. We may contact you about your account or feedback. We might also contact you about this Policy or our website Terms. We use information as otherwise described or permitted by law or as we may notify you. WE MAY SHARE INFORMATION WITH THIRD PARTIES. We will share information within the 2bTrust LLC family of companies. We use information to respond to your requests or questions. For example, we might share your information with third parties in order to provide you with services requested by you or answer your questions. We will share information with third parties who perform services on our behalf. For example, we share information with our vendors. We may also share information with companies that operate our websites. We will share information if we think we have to in order to comply with the law or to protect ourselves. For example, we will share information to respond to a court order or subpoena. We may also share it if a government agency or investigatory body requests. We might also share information when we are investigating potential fraud. We may share information with any successor to all or part of our business. For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of 2bTrust LLC or part of its business (or in anticipation of such an event) we may give your information as part of that transaction. We may share information for other reasons we may describe to you or as permitted by law. YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING AND TRACKING TOOLS. You can opt out of receiving our marketing emails. To stop receiving our promotional emails, simply use the opt-out or unsubscribe method provided in emails you receive from us. You can control cookies and tracking tools. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings. Options you select are browser and device specific. And, if you block or delete cookies, not all of the tracking that we have described in this policy will stop. Our Do Not Track Policy. Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop. THIS SITE AND CHILDREN. Our site is meant for adults. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here. WE USE STANDARD SECURITY MEASURES. The Internet is not 100% secure. We cannot promise that your use of our site or software will be completely safe. We encourage you to use caution when using the Internet. We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law or for internal compliance or record-keeping purposes. WE STORE INFORMATION IN THE UNITED STATES. Information we maintain may be stored within the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This site is subject to U.S. laws, which may not afford the same level of protection as those in your country. WE MAY LINK TO OTHER SITES OR HAVE THIRD PARTY SERVICES ON OUR SITE WE DON’T CONTROL. If you click on a link to a third party site, you will be taken to websites we do not control. This policy does not apply to the privacy practices of that website. Read the privacy policy of other websites carefully. We are not responsible for these third party sites. FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS. If you have any questions about this Policy or other privacy concerns, please contact us at:
2bTrust LLC 7345 W Sand Lake Rd Suite 227 Orlando, FL – 32819 Attn: Legal / Privacy Matters We may update this Policy. From time to time we may change our privacy policies. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our website. Please check our Site periodically for updates.
Terms of Use Terms of Use Legal Disclaimer This Online Access Agreement or Terms of Use (this “Agreement”) governs the access to and use of the 2bTrust LLC website at www.2btrust.com (the “Site”). PLEASE READ THIS AGREEMENT CAREFULLY BEFORE USING THE SITE AND/OR ENTERING OR LOGGING IN TO RESTRICTED PORTIONS OF THE SITE THROUGH USE OF YOUR USER NAME AND PASSWORD. EACH TIME YOU USE THE SITE, YOUR USE INDICATES YOUR FULL ACCEPTANCE OF AND AGREEMENT TO ABIDE BY THE TERMS AND CONDITIONS OF THIS AGREEMENT IN ITS THEN-CURRENT FORM. IF YOU DO NOT ACCEPT THE TERMS AND CONDITIONS SET FORTH IN THIS AGREEMENT, PLEASE EXIT THE SITE. Whether or not you actually read the terms and conditions of this Agreement, your use of the Site will be deemed an acceptance of them. We may modify this Agreement at any time and without notice. LIMITED RIGHT TO USE THE SITE The Site is the property of 2bTrust LLC and its affiliates (collectively, “2bTrust LLC” or “we,” “us,” or “our”). By accessing or using the Site, you agree that your access to and use of the Site, including any Content (defined below) provided by 2bTrust LLC shall be exclusively governed by the terms and conditions set forth in this Agreement. Certain areas of the Site may include additional terms and conditions that govern the use of those areas. You will also be bound by those additional terms and conditions, and they are automatically incorporated into and considered part of this Agreement. If you do not accept the terms and conditions stated in this Agreement, do not use the Site. We reserve the right to refuse access to and usage of the Site by anyone at any time, in its sole discretion. We reserve the right to change, modify, update, amend all or any part of the Site or discontinue the Site at any time, without notice. In addition, we reserve the right to change the terms and conditions governing your access to and use of the Site and the Content at any time, without notice. CONTENT FOR INFORMATIONAL PURPOSES ONLY The information contained on the Site is not investment advice or shall under no circumstances constitute an offer or solicitation to buy or sell any security. Although the Site may include investment-related information, nothing on the Site is a recommendation that you purchase, sell or hold any security or other investment, or that you pursue any investment style or strategy. 2bTrust LLC does not give any advice or make any representations through the Site as to whether any security or investment is suitable for any person or will be profitable, and no information or material on the Site may be relied upon for the purpose of making or communicating investment or other decisions. Nothing on the Site is intended to be, and you should not consider anything on the Site to be, investment, accounting, tax or legal advice. If you would like investment, accounting, tax or legal advice, you should consult with your own financial advisors, accountants or attorneys regarding your individual circumstances and needs. The past performance of any investment, investment strategy or investment style of 2bTrust LLC or any of its affiliates is not indicative of future performance or results. USER NAMES AND PASSWORDS Certain areas within the site are restricted and may only be accessed by persons who have been issued a unique user name and password by 2bTrust LLC. To register for a user name and password, you will need to complete and submit a request that includes an investor qualification certification. As part of the registration process, you will be required to provide 2bTrust LLC with certain personal and financial information, all of which must be accurate, complete and up to date. Upon submitting your request for registration, we will consider your request and, if approved in our sole discretion, will provide you with a user name and password which will allow you to log in to the Site. It is your responsibility to update 2bTrust LLC immediately with any changes to the investor qualification information you provided by contacting us at: contact@2btrust.com. All personal and financial information collected by 2bTrust LLC in the registration process will be governed by 2bTrust LLC Privacy Policy. If you receive a user name and password to access certain restricted areas of the Site, you agree that you will treat and maintain this information confidentially and will not permit others to sign onto the Site through the use of the user name and password assigned to you. You agree that the username and password are for your use only and you accept full responsibility for maintaining the confidentiality and security of your user name and password and any use of your user name and password. You agree to notify us immediately of any actual or suspected loss, theft or unauthorized use of your user name and/or password. Unless information contained on the Site is otherwise public information, all Content contained on the Site shall constitute confidential information (including without limitation the Site’s layout, features, functions, tools and capabilities) (hereafter collectively called the “Confidential Information”), and you agree not to copy, republish or redistribute the Confidential Information or disclose the same to any third party unless and only to the extent 2bTrust LLC has given you express written consent to do so. Any violation of the terms of this Agreement may result in an immediate revocation of your access to the Site and may subject you to liabilities for breach. We are not obligated to inquire as to the authority or propriety of any use of or action taken under your password. We will not be responsible for any loss to you that arises from such use or action or from your failure to comply with these provisions. NO WARRANTY; LIMITATION OF LIABILITY You understand and expressly agree as follows: YOUR USE OF THE SITE IS AT YOUR SOLE RISK. THE SITE AND ITS CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. NEITHER 2bTrust LLC NOR ANY OF ITS AFFILIATES WARRANT THE ACCURACY, ADEQUACY OR COMPLETENESS OF THE MATERIALS PROVIDED ON THE SITE, EITHER EXPRESSLY OR IMPLIEDLY, FOR ANY PARTICULAR PURPOSE AND TO THE FULLEST EXTENT PERMISSIBLE BY APPLICABLE LAW, EACH EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, INCLUDING, BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT. 2bTrust LLC does not warrant or represent that (i) the Site will meet your requirements, (ii) the Site will be uninterrupted, timely, secure, or error-free, (iii) the results that may be obtained from the use of the Site will be accurate or reliable, (iv) information obtained by you through the Site will meet your expectations, or (V) the server that makes the Site available is free of viruses or other harmful components. IN NO EVENT WILL 2bTrust LLC OR ITS AFFILIATES BE LIABLE TO YOU FOR ANY LOSS OR DAMAGE ARISING OUT OF THE USE THIS AGREEMENT, THE USE OF THE SITE, OR INABILITY TO USE THE SITE, WHETHER DIRECT, INDIRECT OR CONSEQUENTIAL, FORESEEN OR UNFORESEEN, INCLUDING LOSS OF PROFIT OR OTHER ECONOMIC LOSS, OR ANY OTHER DAMAGES OF ANY KIND EVEN IF 2bTrust LLC OR AN AFFILIATE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH LOSS OR DAMAGES. If you are dissatisfied with the Site or any Content on the Site, or with the terms and conditions of this Agreement, your sole and exclusive remedy is to discontinue using the Site. You acknowledge, by your use of the Site, that your use of the Site is at your sole risk. Applicable law may not allow the limitation of liability set forth above, so this limitation of liability may not apply to you. If any part of this limitation of liability is found to be invalid, inapplicable or unenforceable for any reason, then the aggregate liability of 2bTrust LLC and its affiliates in such circumstances for liabilities that otherwise would have been limited shall not exceed the sum of one hundred dollars (US $100.00) in the aggregate. No advice or information, whether oral or written, obtained by you from 2bTrust LLC or through or from the Site shall create any warranty not expressly stated in this Agreement. Some states limit or prohibit the disclaimer of implied warranties, so part or all of the foregoing disclaimers may not apply to you. INDEMNIFICATION You agree to indemnify, defend and hold harmless 2bTrust LLC and its affiliates and their employees, managers, partners, directors, officers, agents, vendors or suppliers from and against any and all suits, losses, claims, demands, liabilities, damages, costs and expenses (including reasonable attorneys’ fees) that arise from or relate to: (1) your use of the Site; (2) your breach of this Agreement or any representation, warranty or covenant made by you in this Agreement; (3) your violation of any applicable law, statute, ordinance, regulation or of any third party’s rights; or (4) claims asserted by third parties which, if proven, would place you in breach of representations, warranties, covenants or other provisions contained in this Agreement. You further release 2bTrust LLC and its affiliates and their or any of their employees, managers, partners, directors, officers, agents, vendors or suppliers and you agree to hold them each harmless from any claims, demands and damages of every kind and nature that may arise out of or in any way are connected with a dispute between you and any third party. INTELLECTUAL PROPERTY RIGHTS All of the content you see, hear or otherwise experience on the Site, including without limitation information, data, text, logos, software, page headers, images, icons, typefaces, illustrations and graphics (collectively, “Content”), are protected by trademark, service mark, trade dress, copyright and/or other intellectual property rights or licenses held by 2bTrust LLC, its affiliates or by third parties who have licensed such Content to 2bTrust LLC. The compilation (meaning the selection, collection, arrangement and assembly) of the Content and the Site is the exclusive property of 2bTrust LLC and is protected as a collective work under U.S. and international copyright laws. The Content and Site are intended solely for your personal use. You may download, print and store selected portions of the Content, provided you (1) only use these copies of the Content for your own personal use; provided, however, you may discuss the Content with your financial, legal or tax advisors, and other with whom you share investment decisions; (2) do not copy or post the Content on any network computer or broadcast the Content in any media; and (3) do not modify or alter the Content in any way, or delete or change any copyright or trademark notice. No right, title or interest in any downloaded materials is transferred to you as a result of any such downloading. 2bTrust LLC reserves complete title and full intellectual property rights in any Content you download from the Site. Except as noted above, you may not copy, download, reproduce, modify, publish, distribute, transmit, transfer, exploit or create derivative works from the Content without first obtaining written permission from 2bTrust LLC. The trademarks, logos and service marks (collectively referred to as “Trademarks”) displayed on the Site are registered and unregistered Trademarks of 2bTrust LLC and no trademark license either express or implied is granted by 2bTrust LLC. You do not have any right to use any Trademark displayed on this website without prior written permission of 2bTrust LLC. Trademarks are a very valuable business asset of 2bTrust LLC. In the event of unauthorized use or misuse of its Trademarks, 2bTrust LLC will pursue its legal remedies without delay. REPRESENTATIONS AND WARRANTIES You represent and warrant to 2bTrust LLC and its affiliates that: – you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to this Agreement; – you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of this Agreement; – you have not taken and will not take any action that might compromise the security of the Site, render the Site inaccessible to others or otherwise cause damage to the Site or any Content contained on the Site, and you have not and will not add to, subtract from, or otherwise modify the Content on the Site; and – all information that you provide in connection with your registration, qualification and use of the Site is true and complete in all respects. Any personal nonpublic information that we gather from you through the Site will be governed by 2bTrust LLC Privacy Policy. MONITORING THE SITE We reserve the right to monitor and record activity on the Site in our sole discretion, and may report any activity that we suspect may violate any law or regulation, as it deems appropriate. GOVERNING LAW This Agreement shall be governed by and construed in accordance with the laws of the State of Florida, State of Delaware, and the Federal Laws of the United States of America, without giving effect to conflicts of law principles. GENERAL INFORMATION This Agreement constitutes the entire Agreement between you and 2bTrust LLC governing your use of the Site, and shall supersede any prior agreements between you and 2bTrust LLC concerning this subject matter. 2bTrust LLC may assign this Agreement at any time without your consent. You may not assign this Agreement or delegate any of your obligations under this Agreement. The failure of 2bTrust LLC to exercise or enforce any right or provision of this Agreement shall not constitute a waiver of such right or provision. If any provision of this Agreement is found by a court or arbitration panel to be invalid or unenforceable, the parties nevertheless agree that the court or arbitration panel shall endeavor to give effect to the parties’ intentions as reflected in this Agreement, and the other provisions of this Agreement shall remain in full force and effect.
2BTRUST LLC is a company that operates a website and mobile apps for investing in real estate deals. By using our platform, you agree to our terms and privacy policy. Please note that all images and projections shown are for illustration purposes only and may not represent actual returns. Past performance is not a guarantee of future results and all securities involve risk. While we use reliable third-party data, we cannot guarantee its accuracy or completeness. We do not provide tax advice and investors should consult their own tax advisors for specific tax consequences. We take security seriously and encourage the reporting of any security concerns to compliance@2btrust.com. Our publicly filed offering circulars can be found at 2btrust.com/deals. Copyright 2024 2BTRUST, LLC. All Rights Reserved.
