Privacy Policy, LLC (“RCM”, “we” or “us”) values your privacy.  In this Privacy Policy (the “Privacy Policy”) we explain how we collect, use and disclose the information we collect about you when you use our websites, including, (collectively, the “Site”) and the services available via our Site (the “Service”).   We also explain how we collect, use and disclose the information we collect as part of our contacts database, which includes name, contact and property information, as well as information about real estate investment preferences (the “Database”), and how you can control how we treat such information.  By using our Site or Service, you consent to the use, disclosure and treatment of your personal information in accordance with the terms and conditions of this Privacy Policy and as required by law. 

PLEASE NOTE: The terms and conditions of this Privacy Policy do not apply to the information we collect on behalf of our clients, or the information you choose to share with our clients or other third parties through the Site. 

What information do we collect about you through our Site & Service and how is it used?

Information We Collect Directly From You When you initially register for the Service, RCM asks you to provide certain personal demographic and profile information. The types of personal information collected by RCM include the following: your first and last name, company name, telephone number, postal address, email address and real estate investment preferences.

Information We Collect Automatically When you visit our Site or use our Service, we may collect some basic information about you and your computer. The type of information we collect may include: IP address and referring URL (the site from which you came to our Site). We use this information internally to compile statistics, to determine the number of visitors to our Site, and to develop aggregate demographic insight about the success of our advertising campaigns and partner programs. This information also helps us to understand our members’ needs and to develop and improve our Service to better serve those needs. We also may share this information with our service providers or other third parties, as described in this Privacy Policy. 

What information does RCM collect about you in our Database and how is it used?

We may also collect certain personal information about businesses and individuals from third party sources and publicly available information, and at times we may reach out to these individuals and businesses to confirm or gather additional information. This information generally includes name, address, phone, email and other contact information, as well as investment preferences (e.g. target markets, deal size, asset type, etc.).  We may share the information in our Database with our clients, who may use the information to contact potential investors.  If you are an individual and would like to access the information we maintain about you in our Database, or to request that we update or delete this information, you may do so by contacting us as directed in the Access section below. 

Communicating with You about Opportunities

We may use the contact information we collect from you during registration, as well as the information in the RCM Database (including your first and last name, company name, telephone number, postal address, email address and real estate investment preferences) to sort and direct commercial real estate opportunities to you.  For example, we may use this information to follow-up on properties or services that we provide to you and to inform you of other opportunities, products and services that we think will be of interest to you. In addition, we may send you third party marketing communications and offers, and we may share your name or contact information with these third parties.  If you choose to take advantage of an offer or otherwise communicate with the company whose product or service is being offered, they may obtain your name and other information (and their use of any information you provide them is not subject to this Privacy Policy). 

You may opt-out at any time, free of charge.  Please see the “Your Choices About Marketing” section below for information on how to opt-out.  We are not responsible for any information that you provide to third parties, such as when requesting more information about third party investment opportunities we may send to you, and we encourage you to contact such third parties directly for information on their privacy practices.

Other Uses and Disclosures of the Information We Collect 

In addition to the uses described above, we may use the information we collect, including personal information, as follows:

We may also share your information, including personal information, as follows:

How We Use Cookies and Other Tracking Mechanisms
We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Site and Service. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).  Currently, our Site does not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g. by disabling cookies).

Cookies are small text files that are sent to your computer from the Site and saved on your computer’s hard drive. Cookies allow RCM to personalize your experience on our Site. We use cookies to track registration and transactional information regarding your membership and use of the Service. Most browsers are initially set to accept cookies. If you prefer not to have cookies placed on your computer, most browsers allow you to decline cookies. However, if you do so, certain portions or features of our Site may not be accessible to you.

Clear GIFs
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies.  In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics
We use third party analytics tools, including Google Analytics, to collect, monitor and analyze Site information, in order to improve functionality and user-friendliness, and to better tailor the Site and Service to our users’ needs. Accordingly, usage data is shared with Google, which has its own privacy policy addressing how it uses such information. We encourage you to review this privacy policy to understand how Google uses such information. 

Third Party Advertising

RCM works with third parties, such as network advertisers, to display advertisements on behalf of RCM on third party websites.  These third parties display advertisements based on your use of our Site and other third-party websites, as well as based on other data.  This enables us and these third parties to direct advertisements by displaying ads for products and services in which you might be interested.  Network advertisers may use cookies, JavaScript, web beacons, Flash LSOs, and other technologies to measure the effectiveness of ads and to personalize advertising content to you; the information they collect and use is subject to their own privacy policies, not this one.  They may also use your location or geolocation information to serve ads to you.

We may provide these third-party advertisers with information about your usage of our Site, as well as other aggregate or demographic information; however, we do not share personal information with these third parties.   You can opt out of receiving behaviorally targeted ads from many other third-party advertisers who are members of the Digital Advertising Alliance (“DAA”).  For more information, please visit  Opting out of one or more DAA member networks only means that those members no longer will deliver personalized content or ads to you.  It does not mean you will no longer receive any personalized content. You may also continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browser is configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your DAA opt-out will no longer be effective.

How Long We Retain Your Data
The information you provide when you register for the Service, and the information we collect in our Database, is retained by RCM for so long as you continue using the Service, as long as legally necessary, and/or as long as reasonably necessary for our business purposes.  For example, we may keep certain information even after you stop using the Service if it is necessary to comply with our legal obligations, meet regulatory requirements (such as information retention), resolve disputes, prevent fraud and abuse, or enforce this Privacy Policy.  

How to Access Your Data
If you would like to access the personal information we hold about you in our Database, or request that we update or delete such information, contact us at research at  If you would like to access or update your account profile and other account information, you may review, update, or correct your information at any time by logging onto the Site and clicking on your profile.

Transfer of Personal Information
RCM is located in the United States and will store any data that you provide or we collect in the United States.  Any information collected by RCM will be transferred to, and stored, accessed and used in the United States, and in any other jurisdictions in which RCM operates or in which RCM’s vendors or clients are located.  The privacy laws in the United States and these other jurisdictions may be different and less protective than those in your home jurisdiction.  By using this Site or our Service, you expressly consent to this transfer of your personal data.

US-EU and US Swiss Safe Harbor Programs
RCM complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data obtained from European Union member countries and Switzerland. RCM has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view RCM’s certification, please visit

If you believe that RCM is misusing your personal data or violating the Safe Harbor Principles, please contact us at one of the Privacy Contact options listed below. RCM has further committed to refer unresolved privacy complaints under the US-EU Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by RCM, please visit the BBB EU SAFE HARBOR Site at for more information and to file a complaint.  

Your Choices About Marketing
If, at any time, you wish to stop receiving communications from RCM, login and go to your profile, then click “Preferences” and uncheck the boxes for “I want to receive investment opportunities”, “I want to receive announcements from Real Capital Markets”, and/or “I want to receive announcements from Real Capital Markets partners” options. You may also contact us at one of the Contact Us options listed below, asking to be removed from our marketing and promotional lists.

Links to other Sites
Links from our Site are provided for your convenience only. RCM is not responsible for the content of any third party website or the privacy practices of such third parties. In addition, a link from our Site to another website does not indicate that RCM endorses the services or policies of such third party website. You should always investigate the information practices of all websites that you access and carefully examine their privacy policies. Information collected from the linked websites will be subject to the information practices of those third party websites.

We have implemented safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.  You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Use of this Site by Minors
RCM does not intend to collect information from individuals under eighteen (18) years of age. If you are under eighteen, you should not provide information on this Site.

Contact Us
If you have any questions or concerns about this Privacy Policy or how your demographic and profile information is used, or if you would like to request access to or correction of your personal data, you may contact us at:

Research Manager, LLC
5780 Fleet Street, Suite 130
Carlsbad, CA 92008
research at
(760) 602-5080

Changes to this Privacy Policy
RCM reserves the right to change this Privacy Policy at any time, by posting the modified Privacy Policy on our Site.  If we make changes to this Privacy Policy that materially affect how we treat the information we have previously collected from you, will endeavor to provide you notice prior to such change taking effect.  We encourage you to review our Privacy Policy whenever you visit our website or use the Service to make sure that you understand how your information will be used.


Last Updated: August 25, 2015