Klosed Opportunistic Fund and its affiliates (collectively, “we”, “us”, “our”) are committed to being responsible holders of information we collect in conducting our business, including information collected through the “Website” and any services we provide you either through the Website or through our customer service practices (“Services”). This Privacy Policy sets forth the practices we follow in connection with collecting such information. By downloading, accessing, or using the Website, or providing your information to us through the Website or through other means, you agree to the terms and conditions of this Privacy Policy.

Please note that our practices set forth in this Privacy Policy are for this Website only. Our Website may include links to content provided by third parties (such as social media content, plug-ins and applications). This Privacy Policy does not address the privacy practices of the third parties that provide such content. If you link to any other website, please review the privacy policies provided for in those other sites.


We collect certain information in the course of operating our business for advertising, marketing and promotional purposes, including when you access, use, or interact with our Website or other online services. Some of the information we collect includes “personal information,” which is information that can identify you or that we can link to you as an individual.


  • your individual name and/or business entity name;
  • contact information, including personal and/or business address (physical and/or postal), phone number(s), and email address;
  • demographic information, such as your postal code; and information related to your use and interaction with our Website, such as your IP address.

We collect information that you voluntarily provide to us when you, for example:

  • communicate with us by email, on social media or through other means;
  • register for, or request that we send you, updates and other marketing and promotional materials;
  • reply to our communications or requests for information; or
  • complete forms on our Website or in-person or otherwise provide us with information.

You may decline to provide us with some or all your information that personally identifies you; however, restricting information may materially reduce and diminish the value of our service(s) to you.

We may also collect information about you from third party sources, such as databases, marketing partners, social media platforms, brokers and independent agents and from other third parties. Examples may include:

  • Social media. If you choose to link, create, or log in to your account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with third parties, we may receive personal information about you or your connections from that service. Please note that the information we may receive is governed by the privacy policies of the applicable social media platform, and we encourage you to review them.
  • Real estate professionals.

We may, either directly or through our authorized third-party service providers, also collect information about your use of the Website, including information about your access and visits to the Website, such as internet protocol addresses, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, geolocation, and the date and time, some of which may uniquely identify your browser or your account. We may from time to time collect this information from the use of third party providers such as Google Analytics and the use of technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons on your computer or other devices. When you visit the Website, we store information based on your usage history. We also use cookies and anonymous identifiers when you interact with the services we may offer to our partners, such as advertising services or certain features that may appear on other sites and in any other manner that we deem necessary for our business purposes. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. If you do so, our Website may not function correctly. Please refer to the “Help” feature of your browser for information on disabling cookies. Some web browsers have a “Do Not Track” feature that allows users to tell websites that they do not want certain information about their webpage visits collected over time and across websites. These features are not yet uniform, and we currently do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

This Privacy Policy does not and shall not apply to any information or materials that you provide or display on or post to public areas of the Website or any public and social media forums, or that you transmit to other users of the Website or third parties (collectively, “Unsolicited Information”). All such Unsolicited Information is provided by you at your own risk, and we cannot and do not guarantee the privacy of such Unsolicited Information.


By using and accessing the Website and the Services and providing us your information through the Website or through any other means, you agree that any and all data that you have entered or may enter in the future on the Website, as well as any data you may provide in connection with Services, you consent to our and our third party providers’ compilation, processing, and analyzing of such information, as well as the anonymous disclosure of such aggregated and anonymous data to a third party.

We may use your information to, among other things:

  • perform due diligence that enables us to provide services to you;
  • respond to your inquiries, comments, and posts on different platforms such as social media or to send newsletters/push notifications/texts to you in order to inform you of our present and upcoming services;
  • send to you marketing communications that we believe may be of interest to you;
  • personalize your experience;
  • comply with all applicable laws, orders and regulations, including those outside your country of residence, and legal process; and
  • respond to requests from public, regulatory or government authorities, including public, regulatory or government authorities outside your country of residence.

We may also compile, process, analyze, and disclose aggregated, anonymous data for the purpose of developing anonymous aggregated reports, improving our algorithms, quantify how our Website and Services are utilized and develop related new materials, services and features.


We may disclose information we collect from you to the following persons or entities:

  • our affiliated entities and associated companies;
  • third-party service providers that perform services on our behalf, such as web-hosting companies, analytics providers and information technology providers (we will use commercially reasonable efforts to provide that contractual and other technical and security safeguards will be put in place with the affiliated entities, associated companies or third-party service provider, including to ensure that your personal information is processed in accordance with this Privacy Policy);
  • our employees, sub-contractors, partners, lenders, agents or service providers who work for us where required or necessary under contractual requirements, for the performance of their duties and in line with the purposes for such collection;
  • others with your consent or at your direction;
  • law enforcement, other government authorities, or third parties as we believe to be reasonably necessary or appropriate: (1) to comply with applicable law, regulation, legal process, or enforceable government request, including without limitation a subpoena; (2) to enforce applicable terms of service, including investigation of potential violations; (3) to protect our operations; (4) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including any bankruptcy or similar proceedings), where your information may be part of the transferred assets; (5) to detect, prevent, or otherwise address fraud, security or technical issues; and (6) to protect against harm to the rights, interests, property or safety of us, the users of our Website or Services, or the public as required or permitted by law.

We do not sell, rent, or otherwise share personal information that reasonably identifies you or your entity with any unaffiliated entity except as expressly described in this Privacy Policy or with your prior permission. We may share information that does not reasonably identify you or your organization as permitted by applicable law.


The security of your information is important to us. We use appropriate technical and organizational safeguards to protect your information from unauthorized use, disclosure, and loss. Encryption technology, including current industry-standard encryption protocols, protects personal information in certain areas of our websites during transmission across the Internet. If you have questions about the security of your information, please contact us as provided for under “Contact Us” below.

We retain the information we collect for no longer than is reasonably necessary to fulfil the purposes for which we collect the information and to comply with our legal obligations.

The safety and security of your information also depends on you. We encourage you to take reasonable measures to protect your password and your computer to prevent unauthorized access to your account. We also urge you to be careful about giving out information in public areas of the Website. Remember to sign out of your account and close your browser window if you use a shared computer in a public place such as a library or an Internet cafe.

Unfortunately the transmission of information via the internet is not completely secure. While we do all we can to protect your personal information, we cannot guarantee the safety of information you provide on the Website.


We reserve the right to update or modify this Privacy Policy at any time without prior notice. Your continued use of the Website or the Services after any changes or revisions are made to this Privacy Policy shall constitute your agreement with and acceptance of the terms of the revised Privacy Policy.