Privacy Policy.
Sequent Real Estate + Wealth Management ("Sequent," "we," "us," or "our") operates the 1031 DST Center platform at 1031dstcenter.com (the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect information when you visit the Platform, register for an account, or otherwise interact with our services. By using the Platform, you agree to the practices described below.
1. Scope
This Privacy Policy applies to information collected through the Platform, including the public website, registration and login flows, the member portal, and any related communications. It does not apply to information collected by third parties whose services are independently offered to you, including Concorde Investment Services, LLC ("CIS") and Concorde Asset Management, LLC ("CAM"), each of which maintains its own privacy practices. Where this Platform links to or interacts with such third-party services, their privacy policies will govern your interactions with them.
2. Information We Collect
Information You Provide Directly
When you register for an account, complete your investor profile, or contact us, we collect information you provide, which may include:
- Name, email address, and phone number
- State and country of residence
- Self-certified accredited investor status
- Investment interest, anticipated transaction timing, and any notes you choose to share
- Marketing communication preferences
- Any information you submit through forms, emails, or direct correspondence with our team
Information Collected Automatically
When you visit the Platform, we may automatically collect certain information about your device and usage, including:
- IP address, browser type and version, operating system, and device identifiers
- Pages viewed, time spent on pages, navigation paths, and referring URLs
- Date and time of access and other log data
- Cookies, web beacons, and similar technologies (described further below)
Information from Third-Party Services
The Platform uses third-party services to support authentication, hosting, data storage, and analytics. These services may collect information on our behalf in accordance with their own privacy practices. Current third-party services include Clerk (authentication), Netlify (hosting and serverless functions), Airtable (data storage), and may include analytics services such as Google Analytics. We endeavor to use service providers that maintain appropriate security and privacy practices.
3. How We Use Information
We use the information we collect for the following purposes:
- Account access and verification. To create and maintain your account, verify your self-certified accredited investor status, and provide access to the member portion of the Platform.
- Communication. To respond to your inquiries, send transactional emails (such as account confirmations and password resets), and — with your consent — send educational content, market updates, and information about offerings.
- Platform operation and improvement. To operate, maintain, and improve the Platform, troubleshoot technical issues, and analyze usage patterns.
- Connecting you with a registered representative. When you request it, to connect you with a registered representative of CIS or CAM who can discuss specific offerings or strategies with you.
- Compliance and legal obligations. To comply with applicable laws, regulations, and law enforcement requests; to enforce our Terms of Service; and to protect our rights, property, and safety, or those of our users or others.
- Fraud prevention. To detect, prevent, and respond to fraud, abuse, security incidents, and violations of our policies.
4. How We Share Information
We do not sell, rent, or trade your personal information. We share your information only in the limited circumstances described below.
- With Concorde Investment Services, LLC ("CIS") and Concorde Asset Management, LLC ("CAM"). When you request to speak with a registered representative, or when otherwise required to facilitate a securities-related interaction initiated by you, we share your contact information, your stated objectives, and other information you have provided. CIS and CAM are independent of Sequent and maintain their own privacy and recordkeeping practices, which will govern their handling of your information.
- With accredited investor verification providers. Where verification of accredited investor status is required for access to a specific offering (for example, in connection with Rule 506(c) offerings), we may share limited information with a third-party verification provider designated by CIS or by Sequent for the sole purpose of completing that verification.
- With service providers and technology vendors. We share information with vendors that perform services on our behalf, including hosting (Netlify), authentication (Clerk), data storage (Airtable), email delivery, and analytics. These providers are contractually obligated to use information only as necessary to perform services for us and are not permitted to use it for their own purposes.
- With DST sponsors. Sequent does not share your information with DST sponsors. If you ultimately subscribe to a specific offering, certain information will be conveyed to the sponsor through the subscription process administered by CIS, not by Sequent, and that disclosure is governed by CIS's policies and the offering's subscription documents.
- With third-party marketers and lead-generation services. We do not share your information with third-party marketers or lead-generation services.
- For legal and safety reasons. We may disclose information if we believe in good faith that disclosure is necessary to comply with applicable law, regulation, legal process, or government request; to enforce our Terms of Service; to protect the rights, property, or safety of Sequent, our users, or others; or in connection with the investigation or prevention of fraud or security issues.
- In connection with a business transaction. If Sequent is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction, subject to standard confidentiality protections.
- With your consent. We may share information with other parties when you direct or consent to such sharing.
5. Cookies and Similar Technologies
The Platform uses cookies and similar technologies to operate authentication sessions, remember your preferences, understand how the Platform is used, and improve the user experience. Cookies are small text files stored on your device by your browser. Most browsers allow you to control or block cookies through browser settings; however, blocking essential cookies may prevent core Platform features (including login) from functioning.
We may use analytics services such as Google Analytics to collect aggregate information about how visitors interact with the Platform. Analytics data is used to understand usage patterns, identify areas for improvement, and operate the Platform effectively. We do not use analytics data to make individualized investment recommendations.
6. Data Retention
We retain your information for as long as your account is active and as needed to provide you with services, and thereafter as required to comply with applicable legal, regulatory, tax, accounting, and recordkeeping obligations. Communications and records related to securities-related interactions may be retained for the periods required by applicable broker-dealer and investment adviser recordkeeping rules, which are generally measured in years. When information is no longer needed, we will take reasonable steps to delete, anonymize, or otherwise dispose of it securely.
7. Data Security
We use reasonable administrative, technical, and physical safeguards designed to protect the information we collect. These safeguards include encryption of data in transit, restricted access to systems containing personal information, authentication controls, and ongoing review of our service providers. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity occurring under your account.
8. Your Choices and Rights
Account Information
You may review and update most of your account information at any time by signing in and editing your profile. You may close your account by contacting us at the email address below; we will then deactivate the account, subject to any legal or recordkeeping obligations that require retention of certain information.
Marketing Communications
You may opt out of marketing emails at any time by following the unsubscribe link in any marketing message or by contacting us directly. Transactional and account-related communications (such as authentication emails and verification messages) are not optional while you maintain an active account.
California Residents (CCPA / CPRA)
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), provides you with specific rights regarding your personal information. These include the right to know what categories of personal information we collect and how we use them; the right to request a copy of the specific pieces of personal information we hold about you; the right to request deletion of your personal information, subject to certain exceptions; the right to correct inaccurate personal information; and the right not to be discriminated against for exercising these rights.
We do not "sell" personal information as that term is defined under the CCPA/CPRA, and we do not "share" personal information for cross-context behavioral advertising. To exercise any of the rights above, please contact us using the information in Section 13. We may need to verify your identity before responding.
Other Jurisdictions
If you reside outside California, you may have additional rights under your local privacy laws. We will honor applicable rights to the extent required by law.
9. Children's Privacy
The Platform is intended for accredited investors and is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take reasonable steps to delete that information promptly.
10. Third-Party Links and Content
The Platform may contain links to third-party websites, services, or resources, including the websites of Sequent Real Estate + Wealth Management, Concorde Investment Services, FINRA BrokerCheck, and content published by third parties for educational reference. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party site you visit.
11. International Users
The Platform is operated from the United States and is intended primarily for users located in the United States. If you access the Platform from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.
12. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, provide additional notice (such as an email to registered users or a notice on the Platform). Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised policy.
13. Contact Us
For questions about this Privacy Policy or our privacy practices, or to exercise any of the rights described above, please contact us:
44 Montgomery Street, Suite 1610
San Francisco, CA 94104
Email: contact@sequent-rewm.com
Phone: 415.834.1031
14. Regulatory Notices
Securities are offered through Concorde Investment Services, LLC (CIS), Member FINRA / SIPC. Advisory services are offered through Concorde Asset Management, LLC (CAM), an SEC registered investment adviser. Sequent Real Estate + Wealth Management (CRD #: 5281210) is independent of CIS and CAM. You can check the background of our firm on FINRA's BrokerCheck. Concorde's Form Customer Relationship Summary (Form CRS) is available upon request.