Privacy Policy

Last Updated: November 22, 2025

GV Realty Group, Ltd. ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and request access to our investor materials.

1. Information We Collect

1.1 Personal Information You Provide

When you request access to our investor proposal, we collect the following information:

Full Name – To personalize communications and identify you
Email Address – To send you secure access links and investment information
Phone Number – For follow-up communications (optional)
Company/Organization Name – To understand your professional affiliation
Website URL – To verify your organization and professional standing
Investment Interest – To categorize your inquiry (investor, sponsor, partnership, etc.)

1.2 Automatically Collected Information

We automatically collect certain technical information when you visit our website:

IP Address – For security and geographic analysis
Browser Type and Version – To optimize website performance
Device Information – Screen resolution, operating system
Time Zone – To schedule communications appropriately
Referral Source – How you found our website (e.g., search engine, direct visit)
Session Data – To maintain secure access to investor materials

2. How We Use Your Information

We use the collected information for the following purposes:

Investor Relations – To provide access to investment materials and respond to inquiries
Communication – To send you updates about the F.I.R.E. Sports Complex investment opportunity
Security – To generate and validate time-limited, session-bound access tokens for proposal viewing
Analytics – To understand interest patterns and improve our investor outreach
Compliance – To maintain records as required by securities regulations
Fraud Prevention – To detect and prevent unauthorized access or suspicious activity

3. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), our legal basis for collecting and using your information depends on the context:

Consent – You have explicitly agreed to receive investment information by submitting the registration form
Legitimate Interests – To operate our business, protect our systems, and communicate with prospective investors
Legal Obligations – To comply with securities laws and financial regulations

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your information only in the following limited circumstances:

4.1 Service Providers

We may share your information with trusted third-party service providers who assist us with:

Email delivery services
Database hosting and management
Analytics and website performance monitoring
Professional advisors (legal counsel, accountants)

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.2 Legal Requirements

We may disclose your information if required by law, court order, or governmental regulation, or if we believe disclosure is necessary to:

Comply with securities regulations or financial reporting requirements
Protect the rights, property, or safety of GV Realty Group, Ltd. or others
Investigate fraud or security breaches

4.3 Business Transfers

If GV Realty Group, Ltd. is involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction. We will notify you via email of any change in ownership or use of your personal information.

5. Data Security

We implement industry-standard security measures to protect your information:

Encryption – All data transmission uses HTTPS/SSL encryption
Access Control – Session-bound, time-limited tokens (60-minute expiration)
Database Security – Secure database connections with restricted access
Regular Monitoring – Continuous monitoring for unauthorized access attempts

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

Lead Information – Retained for 7 years for securities compliance
Access Tokens – Automatically expire after 60 minutes
Email Logs – Retained for 2 years for communication tracking

7. Your Privacy Rights

7.1 General Rights

You have the right to:

Access – Request a copy of the personal information we hold about you
Correction – Request correction of inaccurate or incomplete information
Deletion – Request deletion of your personal information (subject to legal retention requirements)
Opt-Out – Unsubscribe from marketing communications at any time
Data Portability – Request a machine-readable copy of your data

7.2 GDPR Rights (EEA Residents)

If you are in the EEA, you have additional rights under the General Data Protection Regulation (GDPR):

Right to Object – Object to processing based on legitimate interests
Right to Restriction – Request temporary restriction of processing
Right to Withdraw Consent – Withdraw consent for future communications
Right to Lodge a Complaint – File a complaint with your local data protection authority

7.3 Exercising Your Rights

To exercise any of these rights, please contact us at:

Email: [email protected]

We will respond to your request within 30 days. Please note that we may need to verify your identity before processing certain requests.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Session Management – Maintain your authenticated session when accessing investor materials
Security – Validate access tokens and prevent unauthorized access
Analytics – Understand how visitors interact with our website

You can control cookies through your browser settings. However, disabling cookies may affect your ability to access investor materials.

9. Third-Party Links

Our website may contain links to third-party websites (e.g., Google Calendar for scheduling calls). We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

10. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including the United States and Ghana. We ensure appropriate safeguards are in place for such transfers in accordance with applicable data protection laws.

11. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will promptly delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

Posting the updated policy on this page with a new "Last Updated" date
Sending you an email notification (if you have provided your email address)

Your continued use of our services after changes take effect constitutes acceptance of the revised Privacy Policy.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

F.I.R.E. Organization
Re: Data Privacy Request
Cc: GV Realty Group, Ltd.
Legal & Compliance Department
Email: [email protected]
Location: Philadelphia, Pennsylvania, USA

For GDPR-related inquiries: If you are an EEA resident and have concerns about how we handle your data, you have the right to lodge a complaint with your local supervisory authority.

This Privacy Policy is effective as of November 22, 2025 and applies to all information collected through our website and investor relations activities.

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