Coterie Exchange Fiduciary Privacy Policy

Effective Date: March 2, 2026

At Coterie Exchange, our relationship with you is built on the foundation of fiduciary duty. We are the trusted custodians of your data, protecting your financial interests, property details, and personal goals with the highest level of confidentiality. Your data is not an asset to be monetized; it is a sensitive record of your intentions.

1. Information We Collect

We collect only the information necessary to provide expert real estate consulting and equity analysis:

• Identification: Name, email, phone number, and mailing address.
• Property Details: Address, equity markers, and property characteristics.
• Intent Data: Move timelines, relocation goals, and investment objectives.
• Usage Metadata: Technical data (IP address, browser type) to improve your experience on our site.

2. The “No-Share” Fiduciary Guarantee

We do not sell, rent, or disclose your personal information to third parties for their marketing purposes. Your data remains within our private, secure ecosystem and is shared only when necessary to fulfill your requests (e.g., coordinating with appraisers or escrow agents) or as required by law.

3. Anti-Fraud & Security Directive

Real estate is a high-risk sector for cybercrime. Coterie Exchange employs a “Zero-Unsecured” policy:

• No Sensitive Data via Email: We will never request wire instructions, passwords, or credit card numbers via standard email or text.
• Verification Protocol: If you receive an electronic communication requesting funds or sensitive data, do not respond. Contact your Coterie Exchange advisor immediately by telephone using a verified number to authenticate the request.
• Encryption: Your data is stored using industry-standard encryption. However, you acknowledge that no digital transmission is 100% secure, and you agree to exercise caution in your own electronic communications.

4. Jurisdiction-Specific Rights

We recognize the unique privacy standards of our clients moving from high-compliance jurisdictions:

• California (CCPA/CPRA): California residents have the right to request a list of categories of personal information we collect, the right to opt-out of the “sale” of data (which we do not do), and the right to request deletion of their data.
• New York (SHIELD Act): We implement administrative, technical, and physical safeguards consistent with the New York SHIELD Act to protect your private information from unauthorized access.
• International Investors (PIPL/GDPR): If you are an international investor, your data is transferred to and processed in the United States. We strive to respect the privacy principles of the PIPL (China) and GDPR (EU) by maintaining high standards of data sovereignty and minimizing cross-border data transfer risks.

5. Updates to This Policy

We reserve the right to amend this Privacy Policy at any time. Changes will be effective immediately upon posting to coterieexchange.com, and the “Effective Date” at the top of this page will be updated. We encourage you to review this policy periodically.

6. Your Rights

You retain full control over your information. You may request to:

• Access & Review: See the information we hold about you.
• Correction: Update or complete your information.
• Erasure: Request that we delete your data, provided it is no longer required for legal or transactional compliance.

7. Contacting Us

For any questions, requests, or to exercise your rights, please contact our Privacy Lead: Email: support@coterieexchange.com