Our CCPA Policy
Effective Date: 9/22/2025
Last Reviewed on: 9/22/2025
This California Privacy Policy describes how Terravet Real Estate Management LLC, d/b/a Terravet Real Estate Solutions (collectively, "Terravet," "Company," "we," or "us") collect and process personal information about our consumers who reside in California. The California Consumer Privacy Act ("CCPA") requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.
This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy notice at: Terramed Privacy Policy.
Our website may include links to other websites or portals, including our official social media pages and our investor portal. This Privacy Policy does not apply to the websites of any other company or organization, even when we provide links to such websites on our website. No link implies our endorsement of any third-party company, website, or products and services. Any information shared with those companies and websites are subject to the privacy policies of such websites, and we encourage you to review all policies, rules, terms, and regulations of such websites and to use caution in determining what information to share. Terravet is not responsible or liable for the privacy policies and practices of third-party websites.
Additionally, the privacy and confidentiality of any information disclosed in or under agreements we enter into with investors, clients, customers, suppliers, or other persons are governed by the terms of such agreements.
Personal Information Collected
We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). Personal information does not include:
- Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
- Lawfully obtained, truthful information that is a matter of public concern.
- Deidentified or aggregated consumer information.
Personal Information Categories Chart
The chart below identifies which categories of personal information we collected from our consumers within the last 12 months.
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records"). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law ("Protected Classes"). | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decisionmaking, military and veteran status, or genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information"). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive personal information. | Further identified in the chart below. | YES |
Sensitive Personal Information Categories Chart
Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.
The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.
| Sensitive Personal Information Category | Collected to Infer Characteristics? |
|---|---|
| L.1. Government identifiers, such as your Social Security number (SSN), driver's license, state identification card, or passport number. | YES |
| L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password. | NO |
| L.3. Precise geolocation, such as physical store visits or physical locations when visiting websites or using mobile apps. | NO |
| L.4. Racial or ethnic origin. | NO |
| L.5. Citizenship or immigration status. | YES |
| L.6. Religious or philosophical beliefs. | NO |
| L.7. Union membership. | NO |
| L.8. Mail, email, or text messages not directed to the Company. | NO |
| L.9. Genetic data. | NO |
| L.10. Neural Data, such as information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information. | NO |
| L.11. Unique identifying biometric information. | NO |
| L.12. Health information. | NO |
| L.13. Sex life or sexual orientation information. | NO |
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you, such as from the forms or other information you provide to the Company.
- Indirectly from you, such as from your interactions with the Company's websites, mobile applications, or social media platforms.
- From our service providers, such as customer service support providers and investor portal providers.
How We Use Personal Information
Personal Information Collection, Use, and Disclosure Purposes
We may use and disclose the personal information we collect to advance the Company's business and commercial purposes, specifically to:
- Provide you with a safe, smooth, and efficient experience and to provide our products and services to you.
- Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
- Fulfil the purposes for which you provided your personal information or that were described to you at collection, respond to your requests for information relating to our products or services and to communicate with you, and as the CCPA otherwise permits.
- Improve our products or services, marketing, or customer relationships and experiences.
- Inform you of any changes to our website, services or goods and products.
- Administer and improve our websites and for internal operations, including running and improving our business, troubleshooting, data analysis, testing, research, statistical and survey purposes.
- Organize events (including with third parties).
- Protect our Company, employees, or operations.
- Promote our services, business, and offerings by publishing advertising on our own websites and by placing ads on third parties' services. We may use your information to model, segment, target, offer, market, and advertise our website and services.
- Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
- Comply with all applicable laws and regulations.
- Stop illegal, fraudulent, or malicious activities by users accessing our websites. This may include the use of identifying data of specific users, in order to prevent their future use of the websites.
- Respond to law enforcement requests and as required by applicable law or court order.
Sensitive Personal Information Use and Disclosure Purposes
We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):
- Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
- Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
- Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
- Ensuring physical safety.
- Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
- disclose the sensitive personal information to another third party; or
- use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
- Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
- Activities required to:
- verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
- improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
- Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.
We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.
Additional Categories or Other Purposes
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.
We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.
Disclosing, Selling, or Sharing Personal Information
Business Purpose Disclosures
We may disclose the personal information we collect, including sensitive personal information, to third parties for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section and in the table below, such as to engage third parties to support our business functions.
We only make these business purpose disclosures under contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA's other contract requirements for engaging service providers or contractors.
The chart below identifies the categories of entities to whom we have disclosed our consumers' personal information for a business purpose over the preceding 12 months, along with the personal information categories disclosed and the disclosure's business purposes.
Business Purposes Disclosure Recipient Category, Personal Information Category, and Purposes Chart
| Category of Business Purpose Disclosure Recipients | Personal Information Categories Disclosed | Sensitive Personal Information Categories Disclosed | Business Purpose Disclosures |
|---|---|---|---|
| Investor relations, fund administration, accounting, and Terravet lenders | A. Identifiers. B. California Customer Records. C. Protected Classes L. Sensitive personal information. | L.1. Government identifiers. L.5 Citizenship of immigration status. | To support customers and investors in managing their investments with Terravet, and managing Terravet’s financial resources. |
| Outside legal counsel | . Identifiers. B. California Customer Records. C. Protected Classes F. Internet or other similar network activity. L. Sensitive personal information. | L.1. Government identifiers. L.5 Citizenship of immigration status. | To manage Terravet’s legal risk and address matters related to relationships with customers and investors. |
| Website administrators and marketing support | A. Identifiers. B. California Customer Records. C. Protected Classes. D. Commercial information. F. Internet or other similar network Activity. | If shared through our websites: L.1. Government identifiers. L.5. Citizenship or immigration status. | To support administration of Terravet’s website(s) and deliver advertising to target audiences. |
Selling or Sharing Personal Information
We do not sell your personal information, including sensitive personal information, to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.
Our personal information sales and sharing does not include information about consumers we know are under age 16.
Your Rights and Choices
If you are a California resident, the CCPA grants you the following rights regarding your personal information:
Right to Know and Data Portability Requests
You have the right to request that we disclose certain information to you about our collection and use of your personal information (the "right to know"), including the specific pieces of personal information we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may make exercise your right to know twice within in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:
- The categories of:
- personal information we collected about you; and
- sources from which we collected your personal information.
- The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
- If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
- disclosed for a business purpose to each category of persons; and
- sold or shared to each category of third parties.
- When your right to know submission includes a data portability request, a copy of your personal information subject to any permitted redactions.
For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct.
Right to Delete and Right to Correct
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.
You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.
For more on exercising these rights, see Exercising the Rights to Know, Delete, or Correct.
Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes
You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's Permitted SPI Purposes (the "right to limit"). As we do not use or disclose sensitive personal information beyond the CCPA's Permitted SPI Purposes, we do not currently provide this consumer right.
For more on the Permitted SPI Purposes, see Sensitive Personal Information Use and Disclosure Purposes.
Personal Information Sales or Sharing Opt-Out and Opt-In Rights
You have the right to request that businesses stop selling or sharing your personal information at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer's parent or guardian for consumers under age 13 (the "right to opt-in")
As we do not sell or share consumers' personal data, we do not currently provide these consumer rights.
Right to Non-Discrimination
You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.
How to Exercise Your Rights
Exercising the Rights to Know, Delete, or Correct
To exercise the right to know, data portability, delete, or correct described above, please submit a verifiable request to us by either:
- Mailing a request to 33 Rock Hill Road, Suite 320, Bala Cynwyd, PA 19004.
- Emailing us at [email protected].
- Visiting terramedrealestate.com.
Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice within a 12-month period.
Verification Process and Authorized Agents
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. We may request specific information from you or your authorized representative to confirm your or their identity and valid authority before we can process your right to know, delete, or correct your personal information.
We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you.
Responding to Your Requests to Know, Delete, or Correct
We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact [email protected].
We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.
Any disclosures we provide will cover information for the 12-month period preceding the request's receipt date. We will consider requests to provide a longer disclosure period that do not extend past January 1, 2022, unless providing the longer timeframe would be impossible or involves disproportionate effort.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Storing and Protecting Your Personal Data
We will only keep the information we collect about you and through your use of the Site for as long as required for the purposes set out above or as otherwise legally permitted or required, such as maintaining the Site, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. We will also maintain the information as required to comply with internal document retention policies and any legal obligations to which we are subject. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data.
We have also developed internal policies to ensure appropriate technical, physical, electronic, and administrative safeguards are in place to protect your information from unauthorized access. Unfortunately, the sending of information via the internet (including by email) is not totally secure and on occasion such information can be intercepted. Please consider this fact prior to sending personal and confidential information through the Site. We will take commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure, but we cannot guarantee the security of data that is sent and stored electronically. By sending us data electronically you acknowledge that such transmission is entirely at your own risk.
The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.
Privacy Policy Changes
We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy's effective date and post the updated policy on our website. We encourage you to check our website to review the current Privacy Policy in effect.
Contact Information
If you have any questions or comments about the Policy and/or our information handling, privacy, and maintenance practices on the Site, contact Terravet at 33 Rock Hill Road, Suite 320, Bala Cynwyd, PA 19004, by email at [email protected], or by telephone at 215-395-6210. Please note calls may be recorded or monitored for training purposes.