Effective Date: November 7, 2025
1. Introduction
This Privacy Policy (“Policy”) sets forth the privacy practices of The PILLAR Real Estate Fund (“we,” “us,” or “our”) with respect to information collected from users (“you” or “your”) through our website, https://www.thepillarfund.com/ (the “Site”), and any associated investor communications, forms, or interactions (collectively, the “Services”).
By accessing or using the Site or Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree to the terms of this Policy, you must immediately discontinue use of the Site and any related Services.
The PILLAR Real Estate Fund respects your privacy and is committed to maintaining the confidentiality, integrity, and security of personal information entrusted to us, in accordance with applicable data protection and privacy laws.
2. Information We Collect
We collect and maintain personal information in the course of operating the Fund, managing investor relationships, and complying with applicable legal and regulatory requirements. Information may be collected directly from you, automatically through your use of the Site, or from third parties.
2.1. Information You Provide Directly. We may collect information that you voluntarily provide to us, including but not limited to your name, email address, phone number, company affiliation, title, and any information submitted via forms, applications, subscription documents, questionnaires, or correspondence. In connection with investor qualification or subscription, we may also collect documentation evidencing accredited investor or qualified purchaser status, financial statements, or similar materials as required under applicable securities regulations.
2.2. Information Collected Automatically. When you access the Site, we may automatically collect certain information about your device and browsing activities. This may include your Internet Protocol (IP) address, browser type, operating system, referring URLs, access dates and times, and usage data. This information is used for system administration, security, and to improve Site functionality.
2.3. Information from Third Parties. We may receive personal information about you from service providers, financial intermediaries, or other third parties assisting in investor onboarding, marketing, or regulatory compliance. Such information is handled in accordance with this Policy and applicable law.
3. Use of Personal Information
We process personal information for legitimate business, contractual, and regulatory purposes, including but not limited to:
- Administering investor accounts and processing subscription or redemption requests;
- Conducting due diligence and verifying investor eligibility;
- Complying with legal, regulatory, and tax reporting obligations;
- Responding to inquiries, requests, or communications;
- Providing access to information and materials relevant to the Fund;
- Operating, maintaining, and improving the Site and Services;
- Preventing, detecting, and mitigating fraudulent or unauthorized activity; and
- Communicating with investors or prospective investors regarding the Fund or related opportunities, subject to applicable marketing consent requirements.
We do not sell, lease, or trade personal information for marketing purposes.
4. Cookies and Tracking Technologies
The Site may use cookies, tracking pixels, and similar technologies to enhance functionality, analyze usage patterns, and improve the user experience. Cookies are small text files stored on your device. You may adjust your browser settings to refuse or delete cookies; however, doing so may impair Site performance or limit functionality.
5. Disclosure of Information
The PILLAR Real Estate Fund does not disclose personal information except as permitted or required by law. Information may be disclosed under the following limited circumstances:
- To Service Providers: We may disclose personal information to trusted third-party service providers that perform administrative, technological, or professional functions on our behalf (e.g., fund administrators, auditors, custodians, IT providers, compliance consultants). These parties are contractually obligated to use such information solely for the purpose of performing services for us and to maintain its confidentiality.
- To Legal or Regulatory Authorities: We may disclose personal information to law enforcement agencies, regulatory bodies, or governmental authorities as required to comply with applicable laws, court orders, subpoenas, or other legal processes.
- In Connection with Business Transactions: In the event of a merger, acquisition, reorganization, or transfer of assets, personal information may be transferred as part of such transaction, subject to continued protection consistent with this Policy.
6. Data Security
We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include access restrictions, encryption, firewalls, and secure data storage.
However, no method of electronic transmission or storage is entirely secure. Accordingly, while we strive to protect your information, we cannot guarantee absolute security.
7. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. When information is no longer required, it will be securely deleted or anonymized in accordance with applicable data retention policies.
8. Your Rights
Depending on your jurisdiction, you may have certain rights regarding your personal information, including the right to:
- Access, correct, or update personal information held about you;
- Request deletion or restriction of processing;
- Object to certain types of processing;
- Request data portability; or
- Withdraw consent where processing is based on consent.
To exercise these rights, please contact mo.mohamed@thepillarfund.com. We may require identity verification before processing any request.
Residents of the European Economic Area (EEA), the United Kingdom, or other jurisdictions with comprehensive data protection laws may have additional rights under the General Data Protection Regulation (“GDPR”) or equivalent laws, including the right to lodge a complaint with a supervisory authority.
Residents of California have rights under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), including rights of access, correction, deletion, and opting out of certain information-sharing activities.
9. International Data Transfers
Personal information may be transferred to, and processed in, jurisdictions outside your country of residence, including the United States. These jurisdictions may not provide the same level of data protection as your home country. Where required, The PILLAR Real Estate Fund implements standard contractual clauses or other legally recognized safeguards to ensure compliance with applicable data-transfer requirements.
10. Children’s Privacy
The Site and Services are not directed to, and may not be used by, individuals under the age of eighteen (18). We do not knowingly collect personal information from minors. In the event such information is inadvertently obtained, it will be promptly deleted.
11. Amendments to This Policy
The PILLAR Real Estate Fund reserves the right to amend, modify, or update this Policy at any time without prior notice, subject to applicable law. The “Effective Date” at the top of this Policy reflects the date of the latest revision. Material changes may be communicated via the Site or by other reasonable means. Continued use of the Site following such changes constitutes acceptance of the revised Policy.
12. Contact Information
For questions, requests, or concerns regarding this Privacy Policy or our handling of personal information, please contact:
The PILLAR Real Estate Fund
Email: mo.mohamed@thepillarfund.com
Website: https://www.thepillarfund.com/