Legal

Privacy Policy

Last updated: October 24, 2026

This Privacy Policy describes how Assemble Capital LLC and its affiliated project entities (“Assemble Capital,” “we,” “us,” or “our”) collect, use, and share personal information in connection with the website at assemble.capital (the “Site”) and our investor relations activities. It also covers information you share with us by email, phone, text, or in person in connection with our investor relations and property acquisition activities.

1. Information We Collect

Information You Provide

Contact and inquiry information — name, email address, phone number, and the contents of any message you send us, including through the Site's inquiry form.
Investor status information — your self-reported accredited investor status and, if you pursue an investment, information required to evaluate eligibility and verify accredited status (which may include income, net worth, or third-party verification letters), subscription information, and tax information such as your Social Security or taxpayer identification number. Sensitive information of this kind is collected through secure offering and portal processes, not through the public Site.
Investor profile information — information you choose to share through the Site’s investor inquiry form, such as your areas of interest, investment experience, anticipated investment range, and how you heard about us.
Property submissions — if you submit a property through our Submit a Deal page or otherwise, information about you (name, contact details, company, and your role, such as owner, agent, or wholesaler) and about the property, which may include its address, asking price, zoning, lot size, occupancy and tenant history, photos, and documents you upload. Please do not include information about tenants or other third parties beyond what is needed to describe the property.
Communications — records of correspondence, meetings, and calls with us.

Information Collected Automatically

Usage and device data — IP address, browser type, device information, pages viewed, referring URLs, and the date and time of your visit, collected through our hosting provider’s server logs.
Analytics data — we use Google Analytics, which sets cookies and uses similar technologies to collect information about how visitors use the Site, such as pages viewed, time on page, approximate location (derived from IP address), device type, and interactions such as clicking “Schedule an intro call” or submitting a form. See Section 4.
Third-party resources — the Site loads fonts and other resources from third-party providers (such as Google Fonts), which may receive your IP address when your browser requests those files.

2. How We Use Information

To respond to inquiries and administer our investor contact list;
To evaluate investor eligibility, establish and document relationships, and — for offerings conducted under Rule 506(c) — take reasonable steps to verify accredited investor status as required by law;
To administer offerings and investments, including subscriptions, distributions, reporting, and tax documents (K-1s);
To comply with legal and regulatory obligations, including securities laws, anti-money-laundering and know-your-customer requirements, and recordkeeping rules;
To send updates about Assemble Capital and, where permitted, information about future opportunities (you may opt out of marketing communications at any time);
To evaluate properties submitted to us, communicate with owners, agents, and other submitters, and pursue potential acquisitions;
To operate, secure, measure, and improve the Site, including through analytics.

We do not sell your personal information, and we do not share it with third parties for their own cross-context behavioral advertising. We share personal information only:

With service providers that support our operations — such as website hosting, analytics (Google), email, scheduling, form and file storage, our investor portal provider, accredited-investor verification services, fund administration, banking, and e-signature providers — under obligations to protect it;
With our professional advisors — attorneys, accountants, auditors, and tax preparers — as needed to operate the business and administer investments;
With affiliated entities involved in a project you inquire about or invest in;
For property submissions, with parties to a potential acquisition — lenders, co-investors, brokers, title and escrow companies, consultants, and other parties involved in evaluating or completing a potential acquisition;
As required by law or legal process, or to protect the rights, safety, or property of Assemble Capital or others;
In connection with a business transaction such as a merger, financing, or sale of assets, subject to customary protections.

4. Cookies, Analytics, and Your Choices

We use Google Analytics to understand how the Site is used and to measure inquiries. We do not use analytics data to serve you targeted advertising, and we do not run advertising cookies on the Site. Google processes analytics data under its own terms and privacy policy, available at policies.google.com/privacy.

You can block or delete cookies through your browser settings, or install Google’s Google Analytics opt-out browser add-on. The Site works without analytics cookies. Because there is no common industry standard for “Do Not Track” signals, the Site does not respond to them; we treat a Global Privacy Control signal as a request to opt out of any sale or sharing of personal information, which we do not engage in.

Email, calls, and texts. If you give us your email address or phone number, we may contact you about your inquiry or submission. We send marketing emails only where permitted, and every marketing email includes a way to unsubscribe. We will not send you marketing text messages without your consent; you can reply STOP to opt out of texts at any time.

How our forms work. Some Site forms open a pre-filled message in your own email program rather than sending it directly. In that case, your message is transmitted by your email provider, and nothing is sent until you choose to send it.

5. Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act as amended (CCPA/CPRA) may give you rights with respect to your personal information, subject to applicable exemptions, including the rights to know, access, correct, and delete personal information we hold about you, and the right not to receive discriminatory treatment for exercising your rights. Because we do not sell or share personal information for cross-context behavioral advertising, there is nothing to opt out of on that front. We use sensitive personal information, such as Social Security numbers and financial information collected for an investment, only for purposes permitted by law, such as administering the investment and meeting legal obligations. You may designate an authorized agent to make a request on your behalf; we may require proof of that authorization. California residents may also request information about any disclosure of personal information to third parties for their direct marketing purposes under California Civil Code § 1798.83 (“Shine the Light”); we do not make such disclosures. To exercise your rights, contact us at info@assemble.capital with the subject line “Privacy Request.” We will verify your identity before responding and will respond within the timeframes required by law. Note that information collected in connection with securities transactions may be exempt from certain CCPA requirements and may be retained as required by law.

6. Data Retention

We retain personal information for as long as needed for the purposes described above, and as required by securities, tax, and other laws — which, for offering and investment records, can require retention for a period of years after an investment concludes.

7. Security

We use commercially reasonable safeguards designed to protect personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Sensitive investor documentation should be exchanged only through the secure channels we designate — not by replying to marketing emails or through the public Site forms. Do not send Social Security numbers, bank account numbers, or wiring instructions through Site forms or ordinary email. We will never ask you to wire funds based on instructions sent only by email; always confirm wiring instructions by phone using a number you already know.

8. Third-Party Sites

The Site links to third-party websites and services — including the investor portal (operated by Cash Flow Portal), scheduling tools, Google Analytics, and property listing sites such as Zillow — which have their own privacy practices and policies. We are not responsible for the privacy practices of third parties, and we encourage you to review their policies.

9. Children

The Site is not directed to children, and we do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us personal information, contact us and we will delete it.

10. Changes to This Policy

We may update this Policy from time to time by posting a revised version with an updated “Last updated” date. Material changes will be reflected on this page.

11. Contact

Privacy questions and requests: info@assemble.capital, or Assemble Capital, 9000 Sunset Blvd #3, Los Angeles, CA 90069, (310) 704-1794.