Privacy Policy

1 Scope and Operator

This Policy applies to information processed through the Site and to information that you voluntarily provide when communicating with us about the Site. SOHO DEVELOPMENT GROUP LLC operates the Site. This Policy does not govern websites operated by related companies or other third parties, even when the Site links to them.

2 Information We May Process

Information You Provide

The Site does not currently provide an online submission form. If you contact us by email or another communication method, we may receive your name, email address, telephone number, company or organization, the contents of your message, attachments, and any other information you choose to provide.

Technical Information

When you visit the Site, Cloudflare, our hosting, content-delivery, security, and analytics provider, automatically processes limited technical information needed to deliver, protect, diagnose, and measure the Site. Depending on the request and service, this information may include your Internet Protocol address, browser and device type, operating system, requested page, timestamp, referring address, network and routing information, security-event information, and approximate location derived from your Internet Protocol address.

We do not currently use the Site to create user profiles, conduct targeted advertising, or collect accreditation, banking, tax, government-identification, or investment-account information.

3 Cookies and Web Analytics

The Site does not currently use cookies for analytics or advertising and does not use browser local storage or session storage to collect visitor information. Cloudflare Web Analytics measures page views and page-performance metrics without cookies. The Site does not use targeted advertising or cross-context behavioral advertising.

4 How We Use Information

We may use information described in this Policy to:

• Respond to communications and requests;
• Operate, maintain, secure, and troubleshoot the Site;
• Measure aggregate Site traffic and page performance, and prevent misuse or security incidents;
• Maintain business records and protect our legal rights;
• Comply with applicable law, legal process, and regulatory requirements; and
• Carry out another purpose that we explain when you provide the information or that you authorize.

5 How We Disclose Information

We may disclose information in the following circumstances:

• Service providers. Cloudflare provides hosting, content delivery, security, diagnostics, and cookie-free Web Analytics. Email, information-technology, and professional-service providers may process information as needed to support communications or our operations.
• Legal and safety matters. We may disclose information when reasonably necessary to comply with law, respond to lawful process, protect rights or safety, investigate misuse, or enforce agreements.
• Business transactions. Information may be disclosed in connection with a proposed or completed financing, reorganization, merger, sale, transfer, or similar transaction involving all or part of our business or assets.
• Related-company referrals. If you contact SOHO about a matter that concerns a separately operated related company, we may refer the inquiry to that company when reasonably necessary to respond to your request.
• At your direction. We may disclose information when you request, authorize, or consent to the disclosure.

We do not sell personal information. We do not knowingly share personal information for cross-context behavioral advertising.

6 Do Not Track and Cross-Site Tracking

The Site does not currently respond to browser Do Not Track signals. It does not use advertising trackers or knowingly permit third parties to collect personal information through the Site over time and across unrelated websites for targeted advertising. Cloudflare Web Analytics does not track individual visitors across Cloudflare customers' websites.

7 Data Retention

We retain direct communications and related business records only for as long as reasonably necessary to respond, maintain appropriate records, protect our legal rights, resolve disputes, and satisfy legal or regulatory obligations. Cloudflare retains technical logs and analytics data according to the services and settings it provides to us. Retention periods vary by data type and purpose.

8 Information Security

We use reasonable administrative, technical, and organizational measures appropriate to the nature of the information we process. No website, network, or electronic transmission can be guaranteed to be completely secure, and we cannot guarantee the absolute security of information.

9 Your Choices and Requests

Depending on applicable law and the information we maintain, you may request access to, correction of, or deletion of personal information associated with you. You may also ask questions about our privacy practices. Submit requests to tony@sohoinvestors.com. We may need to verify your identity before completing a request, and legal exceptions may apply.

10 Children

The Site is intended for a general adult business audience and is not directed to children under 13. We do not knowingly collect personal information from children under 13 through the Site.

11 Third-Party and Related-Company Websites

The Site may link to websites operated by related companies or other third parties. Those websites are separately operated and have their own privacy practices. SOHO is not responsible for the privacy, security, content, or operation of a website that it does not operate. Review the privacy policy of each website you visit.

12 Changes to This Policy

We may update this Policy to reflect changes in the Site, our practices, or applicable law. The revised version will be posted on the Site with a new effective date. Material changes will be communicated in another manner when required by law.

13 Contact

Questions or requests concerning this Policy may be sent to: