Privacy Policy

Effective Date: February 15, 2019

This Privacy Policy explains how RealToken LLC (“RealToken”, “we” or “us”) collects, uses and discloses information about you when you use our website,, and online services (collectively, the “Services”), when you interact with us as described below.

We may change this Privacy Policy from time to time in our sole discretion. If we make changes, we will notify you by revising the date at the top of this Privacy Policy, and the updated Privacy Policy will be posted via a hyperlink at the bottom of our website homepage. In some cases, we may provide you with additional notice (such as by adding a statement relating to Privacy Policy changes to our website homepage or by sending an email notification). We encourage you to review this Privacy Policy whenever you access the Services to stay informed about our information practices and the choices available to you.

It is your obligation to periodically visit our Website to review any changes that may be made to this Privacy Policy. Your continued use of our Website and Services constitutes your agreement to be bound by our Privacy Policy and any changes to the Privacy Policy. If you do not agree with this Privacy Policy, you are not authorized to use our Website and your sole recourse is to not use our Website or the Services.


Collection of Information

Information You Provide to Us Directly

We collect information you provide directly to us. For example, we collect information when you interact with us as an investor, prospective investor, or former investor, when you create an account to access certain features of the Services, when you access or use any collaboration tools or participate in any interactive features of the Services, when you send us an email, fill out a form, respond to a survey, comment on a blog, register for an event, interact with us on social media, enter a promotional drawing, if any, or otherwise communicate with us. The types of information we may collect include the following:

  • Contact information and personal details, such as your name, residential, business and postal addresses, telephone number, email address, and family details such as name of your spouse, partner or children;
  • Profile information, such as the username and password you establish with the Services;
  • Demographic details, such as date of birth, country of citizenship and/or country of residence, marital status;
  • Information about your net worth and/or income, such as your stated net worth; stated current, historical, and expected future income; source(s) of income; and supporting documentation that you choose to submit (e.g., tax forms, tax returns, pay stubs, financial account statements, and information about your financial assets and liabilities);
  • Government-issued identification (to the extent permitted under applicable law), such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver’s License or other government-issued identification number), a copy of your government-issued identification card and related government issued photographs;
  • Information about your investment experience and preferences, such as investment objectives, investment experience, liquidity needs, and risk tolerance;
  • Financial Account and payment Information, such as your bank accounts you may use to source your investment funds, other related payment information and the cryptocurrency wallet addresses you may use to receive your RealTokens and revenue payout tokens, if any;
  • Information about your relationship to a company, such as your current occupation, job title and whether you are a beneficial owner or authorized signatory of the legal entity using the Service;
  • Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services;
  • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with our marketing communications;
  • Social media information such as username or handle, preferences; and
  • Other information you choose to provide.


Information About Your Use of the Services

When you access or use the Services, we may automatically collect information about you, such as the following:

  • Device Information: We collect information about the devices you use to access our website and Services, including the hardware model, operating system and version, unique device identifiers, network and mobile network information, and cryptocurrency wallet public keys.
  • Log Information: We collect log information about your use of the Services, including your browser type and language, app version, access times, pages viewed, Internet Protocol (“IP”) address, approximate geographic location, and the webpage, IP address, or online service you visited before navigating to the Services.
  • Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information, including cookies and web beacons (or pixel tags). Cookies are small data files stored on your hard drive or in device memory that help us to do things such as improve the Services and your experience, see which areas and features of the Services are popular, and count site visits. Web beacons are generally non-visible, electronic images or codes that may be used on the Services or in our emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine if an email has been opened and acted upon. For more information, please refer to our Cookie Policy.


Information We Collect from our Vendors

We may receive information about you from our vendors. For example, we use vendors to verify the identity and accredited investor status of users of our Services and perform KYC and AML checks. These vendors may provide us with information such as:

  • Whether you or your company are on government lists of restricted persons (e.g., the OFAC list or other watch lists or sanctions lists);
  • Whether there are adverse media reports regarding you or your company;
  • Whether you or your company qualifies as a “politically exposed person” (e.g., a government official or representative of an international organization) under applicable law;
  • Whether the personal information that you provided to us matches information contained in databases they consult; or
  • Whether you are an accredited investor per applicable law.

The information we collect from vendors may include sensitive information (e.g., criminal conviction for fraud) to the extent permitted under applicable law.


Information We Collect from Third Party Vendors and Social Media Networks

We may interact with third party companies that share your personal information with us. For example, if you establish a cryptocurrency wallet through a third party provider to make an investment through the Services, the provider of the wallet will share the address of that wallet with us. We may also maintain pages for RealToken and our series investment offerings on a variety of third-party platforms, such as Facebook, Twitter, Google+, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them, we will treat that information in accordance with this Privacy Policy.


Information We Collect from Other Sources

We may also obtain information from other sources such as public databases, publicly accessible government lists or media and internet searches and combine that with information we collect through the Services. For example, we may use information from LinkedIn to update information about you in our contact database or to verify your employment.


Use of Information

Internal Use of Information

We may use information about you for various purposes, including to:

  • Operate, maintain and improve our website and the features and functionality of the Services;
  • Manage identity verification of and perform KYC and AML checks on, and accredited investor status conformation of, our prospective investors;
  • Process the investments you may make with our RealToken series issuers through the Services;
  • Communicate with you regarding your account with us and your investments in one or more of our RealToken series investments;
  • Respond to your questions, comments and requests;
  • Provide information or services and send related information, including confirmations and receipts;
  • Communicate about products, services, offers, promotions, rewards and events offered by RealToken or others we think will be of interest to you;
  • Monitor and analyze usage, trends and activities related to, and the effectiveness of, the Services;
  • Manage your online account(s) and send you technical notices, updates, security alerts, and support and administrative messages; and
  • Notify you about any changes to the Services.

We may process and store information about you in the United States and other countries, which may have less protective data protection laws than the region in which you are situated.


Sharing of Information

We may share information about you as follows or as otherwise described in this policy:

  • With vendors, consultants, professional advisors and other third-party service providers who are working on our behalf and either collect or need access to your information to carry out their work for us;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including, for example, subpoenas and lawful requests by public authorities to meet national security or law enforcement requirements;
  • If we believe your actions are inconsistent with our user agreements or policies, to protect the rights, property and safety of us or any third party, or to protect, deter or investigate against fraudulent, harmful, unauthorized unethical or illegal activity; and
  • With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Please note that information you post in your profile, blogs, listings, public or private groups, forums and any other interactive areas of the Services (if any) will be available to other users of those features and, in some cases, may be publicly available.


Links to Other Websites and Third-Party Content

We may provide links to or embed videos hosted by third-party websites, services, and applications that are not operated or controlled by RealToken. This Privacy Policy does not apply to third-party services, and we cannot take responsibility for the content, privacy policies, or practices of third-party services. We encourage you to review the privacy policies of any third-party service before providing any information to or through them.

The Services may include an activity feed, social media buttons and widgets, such as the Facebook “Like” button or the “Share This” button. Your interactions with these features are governed by the privacy policy of the third-party service that provides the feature.


Data Retention

We store the information we collect about you for as long as is necessary for the purpose(s) for which we collected it and in accordance with our legal obligations and legitimate business interests or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your personal data depending on its purpose, such as proper account maintenance, RealToken investment record keeping, facilitating client relationship management, and responding to legal claims or regulatory requests.


Data Security

RealToken is extremely aware of the need to protect your personal data against loss and unauthorized manipulation, access or modification. To protect your personal data, we employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our website and the Services. These measures are designed to appropriately protect personal information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal information in our possession. We will continuously assess and change our internal procedures accordingly to meet data protection requirements; however, no security system is impenetrable and, although we intend to do our best to protect your personal data, we cannot guarantee the security of our systems or your personal information. You agree to not hold us and our respective past, present and future employees, officers, directors, contractors, consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of information provided by you through our website or Services.


Residents of the European Economic Area

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under applicable law regarding the processing of your personal data. The term “personal data” has the meaning given to it by the EU General Data Protection Regulation (“GDPR”). When we process your personal data as described in this Privacy Policy, we will only do so when we have a legitimate interest in processing your personal data (for example, our legitimate interest in providing the Services, responding to your inquiries and sending you marketing communications), when the processing is necessary for compliance with a legal obligation to which we are subject, or when we have your consent to process your personal data. When processing is based on consent, you have the right to revoke such consent at any time. You also have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below. If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see:


Your Choices

Account Information

You may update, correct or delete your online account information (if any) at any time by logging into your account. If you delete any account information, we may retain certain information as required by law or for legitimate business purposes.


Promotional Communications

You may opt out of receiving marketing or promotional emails from us by following the instructions in those emails. Please note that even if you opt out of receiving promotional emails, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.


Information Collected Via Cookies

You may determine not to accept cookies by following the following procedures which most web browsers support: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. By blocking or disabling cookies, your experience using our website may be negatively impacted, as some features and services on our website may not work properly once our cookie is disabled. Depending on your mobile device and operating system,


Contact Us

If you have any questions about this Privacy Policy, please contact us at:

You may also write us at:

RealToken LLC
2750 NE 185th street, suite 306.
Aventura, Florida 33180
Attn: Legal – Privacy

RealT Affiliate Program Terms and Conditions






  1. Overview

This Agreement contains the complete terms and conditions that apply to you becoming an affiliate in RealT’s Affiliate Program. The purpose of this Agreement is to allow HTML linking between the RealT website and your website or your other social networking channels or posts (together, your “Sites”). Please note that throughout this Agreement, “we,” “us,” and “our” refer to RealT, and “you,” “your,” and “yours” refer to the affiliate. Applicants who are accepted into the RealT Affiliate Program will each receive a unique referral hyperlink (a “Link”) that they can post on their Sites and share with potential referrals to earn commissions and other rewards.  

  1. Eligibility

The RealT Affiliate Program is open only to any “non-U.S. person” located outside of the United States who has purchased at least one RealToken of any Series of RealToken LLC.  For purposes of this Agreement, a “non-U.S. person” is any natural person who is not a resident of, or located in, the United States, and partnership or corporation that is not organized or incorporated under the laws of, or located in, the United States, and any trust of which all of the trustees are not residents of, or located in, the United States.  

  1. Enrollment and Affiliate Obligations

3.1. To begin the enrollment process, you will apply electronically on the website by reviewing  and agreeing to the terms and conditions of this Agreement. The fact that we auto-approve applications does not imply that we may not re-evaluate your application at a later time. We may reject your application at our sole discretion. We may cancel this Agreement with you if we determine that your Sites are unsuitable for our Affiliate Program, including if they:

3.1.1. Promote sexually explicit materials.

3.1.2. Promote violence.

3.1.3. Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation, or age.

3.1.4. Promote illegal activities.

3.1.5. Incorporate any materials which infringe or assist others to infringe on any copyright, trademark or other intellectual property rights or to violate the law.

3.1.6. Include “ReatT,” “ReatToken” or variations or misspellings thereof in your website domain name.

3.1.7. Are otherwise in any way unlawful, harmful, threatening, defamatory, obscene, harassing, or racially, ethnically or otherwise objectionable to us in our sole discretion.

3.1.8. Contain software downloads that potentially enable diversions of commission from other affiliates in our program.

3.1.9. You may not create or design your Sites, explicitly or implied in a manner which resembles our website nor design your Sites in a manner which leads customers to believe you are RealT or any other affiliated business.

3.2. RealT reserves the right, at any time, to review your placement and approve the use of your Link and require that you change the placement or use to comply with the guidelines provided to you.

3.3. The maintenance and the updating of your Sites will be your responsibility. We may monitor your Sites as we feel necessary to make sure that your are operating in compliance with this Agreement.

3.4. It is entirely your responsibility to follow all applicable intellectual property and other laws that pertain to your Sites. You must have express permission to use any person’s copyrighted material, whether it be a writing, an image, or any other copyrightable work. We will not be responsible (and you will be solely responsible) if you use another person’s copyrighted material or other intellectual property in violation of the law or any third party rights.

  1. RealT Rights and Obligations

4.1. We have the right to monitor your Sites at any time to determine if you are following the terms and conditions of this Agreement. We may notify you of any changes to your Sites that we feel should be made, or to make sure that your links to our website are appropriate and to notify further you of any changes that we feel should be made. If you do not make the changes to your Sites that we feel are necessary, we reserve the right to terminate your participation in the RealT Affiliate Program.

4.2. RealT reserves the right to terminate this Agreement and your participation in the RealT Affiliate Program immediately and without notice to you should you commit fraud in your use of the RealT Affiliate Program or should you abuse this program in any way. If such fraud or abuse is detected, RealT shall not be liable to you for any commissions for such fraudulent sales.

4.3. This Agreement will begin upon your accepting its terms and providing your electronic signature on our website, and will continue unless terminated hereunder.

  1. Termination

Either you or we may end this Agreement AT ANY TIME, with or without cause, by giving the other party written notice. Written notice can be in the form of mail, email or fax. In addition, this Agreement will terminate immediately upon any breach of this Agreement by you.

  1. Modification

We may modify any of the terms and conditions in this Agreement at any time at our sole discretion. In such event, you will be notified by email. Modifications may include, but are not limited to, changes in the payment procedures and RealT’s Affiliate Program rules. If any modification is unacceptable to you, your only option is to end this Agreement. Your continued participation in RealT’s Affiliate Program following the posting of the change notice or new Agreement on our Sites will indicate your agreement to the changes.

  1. Commissions

7.1  RealT will pay a referral fee (“Commission”) for each customer referred to the website by an affiliate through the affiliate’s Link who completes a purchase on the website of one or more RealTokens of a Series of RealToken LLC.  The standard Commission will consist of a cash payment to the affiliate equal to two percent (2%) of the dollar amount of RealTokens purchased by the referred customer. RealT reserves the right to change the Commission rate at any time (which change shall not alter the effective rate for any RealTokens already purchased by a referred customer) and may offer from time to time, as and when posted on the website, special promotions including, but not limited to, increased Commission rates, competitions awarding cash prizes to referral leaders, VIP access to RealT events and early notice of new listings on the website.   

  1. Promotion Restrictions

8.1. You are free to promote your own Sites, but naturally any promotion that mentions RealT could be perceived by the public or the press as a joint effort. You should know that certain forms of advertising are always prohibited by RealT. For example, advertising commonly referred to as “spamming” is unacceptable to us and could cause damage to our name. Other generally prohibited forms of advertising include the use of unsolicited commercial email (UCE), postings to non-commercial newsgroups and cross-posting to multiple newsgroups at once. In addition, you may not advertise in any way that effectively conceals or misrepresents your identity, your domain name, or your return email address. You may use mailings to customers to promote RealT so long as the recipient is already a customer or subscriber of your services or Sites, and recipients have the option to remove themselves from future mailings. Also, you may post to newsgroups to promote RealT so long as the news group specifically welcomes commercial messages. At all times, you must clearly represent yourself and your Sites as independent from RealT. If it comes to our attention that you are spamming, we will consider that cause for immediate termination of this Agreement and your participation in the RealT Affiliate Program. Any pending balances owed to you will not be paid if your account is terminated due to such unacceptable advertising or solicitation.

8.2. Affiliate shall not transmit any so-called “interstitials,” “Parasiteware™,” “Parasitic Marketing,” “Shopping Assistance Application,” “Toolbar Installations and/or Add-ons,” “Shopping Wallets” or “deceptive pop-ups and/or pop-unders” to consumers from the time the consumer clicks on a qualifying link until such time as the consumer has fully exited RealT’s site (i.e., no page from our site or any RealT’s content or branding is visible on the end-user’s screen). As used herein a. “Parasiteware™” and “Parasitic Marketing” shall mean an application that (a) through accidental or direct intent causes the overwriting of affiliate and non-affiliate commission tracking cookies through any other means than a customer initiated click on a qualifying link on a web page or email; (b) intercepts searches to redirect traffic through an installed software, thereby causing, pop ups, commission tracking cookies to be put in place or other commission tracking cookies to be overwritten where a user would under normal circumstances have arrived at the same destination through the results given by the search (search engines being, but not limited to, Google, MSN, Yahoo, Overture, AltaVista, Hotbot and similar search or directory engines); (c) set commission tracking cookies through loading of RealT’s site in IFrames, hidden links and automatic pop ups that open RealT’s site; (d) targets text on websites, other than those websites 100% owned by the application owner, for the purpose of contextual marketing; (e) removes, replaces or blocks the visibility of Affiliate banners with any other banners, other than those that are on websites 100% owned by the owner of the application.

  1. Grant of Licenses

9.1. We grant to you a non-exclusive, non-transferable, revocable right to (i) access our site through HTML links solely in accordance with the terms of this Agreement and (ii) solely in connection with such links, to use our logos, trade names, trademarks, and similar identifying material (collectively, the “Licensed Materials”) that we provide to you or authorize for such purpose. You are only entitled to use the Licensed Materials to the extent that you are a member in good standing of RealT’s Affiliate Program. You agree that all uses of the Licensed Materials will be on behalf of RealT and the good will associated therewith will inure to the sole benefit of RealT.

9.2. Each party agrees not to use the other’s proprietary materials in any manner that is disparaging, misleading, obscene or that otherwise portrays the party in a negative light. Each party reserves all of its respective rights in the proprietary materials covered by this license. Other than the license granted in this Agreement, each party retains all right, title, and interest to its respective rights and no right, title, or interest is transferred to the other.

  1. Disclaimer


  1. Representations and Warranties

You represent and warrant that:

11.1. This Agreement has been duly and validly executed and delivered by you and constitutes your legal, valid, and binding obligation, enforceable against you in accordance with its terms;

11.2. You have the full right, power, and authority to enter into and be bound by the terms and conditions of this Agreement and to perform your obligations under this Agreement, without the approval or consent of any other party;

11.3. You are not a resident of the United States or otherwise a “U.S. Person,” as that term is defined in Rule 501(a) of Regulation D promulgated under the Securities Act of 1933.

11.4. You hereby certify that you are in full observance of, and not in violation of, the laws of the jurisdiction in which you reside and of each of the jurisdictions into which you may send a Link in connection with your participation in the RealT Affiliate Program, including (i) the legal requirements within your jurisdiction and in any jurisdiction where you intend to send a Link to solicit purchasers of RealTokens for the offer and sale of securities and deemed security tokens, (ii) any foreign exchange restrictions applicable to such offers and sales, (iii) any governmental or other consents that may need to be obtained, and (iv) the income tax and other tax consequences, if any, that may be relevant to the receipt of commission fees under this Agreement.

11.5.  You are not required to obtain any licenses or registrations under applicable law, including the rules and regulations of any self-regulatory organization with competent jurisdiction, to participate in the RealT Affiliate Program as contemplated hereunder, and you will promptly obtain such licenses and registrations if you determine that any of them are necessary in order to act as an affiliate and receive commissions hereunder.

11.6. You have sufficient right, title, and interest in and to the rights granted to us in this Agreement.

11.7. You acknowledge that RealT is entering into this Agreement in reliance on the representations, warranties, and agreements contained herein.  You shall give prompt notice to RealT of the occurrence of any event that may affect the accuracy of any representation, warranty, or agreement; provided that such notice shall not relieve you from your obligations hereunder or prevent any party from seeking an appropriate remedy.

  1. Limitations of Liability


  1. Indemnification

You hereby agree to indemnify and hold harmless RealT, and its subsidiaries and affiliates, and their directors, officers, employees, agents, shareholders, partners, members, and other owners, against any and all claims, actions, demands, liabilities, losses, damages, judgments, settlements, costs, and expenses (including reasonable attorneys’ fees) (any or all of the foregoing hereinafter referred to as “Losses”) insofar as such Losses (or actions in respect thereof) arise out of or are based on (i) any misrepresentation of a representation or warranty or breach of a covenant and agreement made by you herein, or (ii) any claim related to your Sites, including, without limitation, content therein not attributable to us.

  1. Confidentiality

All confidential information, including, but not limited to, any business, technical, financial, and customer information, disclosed by one party to the other during negotiation or the effective term of this Agreement which is marked “Confidential,” will remain the sole property of the disclosing party, and each party will keep in confidence and not use or disclose such proprietary information of the other party without express written permission of the disclosing party.

  1. Data Security

You agree to comply with all applicable data protection laws regarding the transmission of data exported to or from the United States or the country in which you reside, including without limitation, the General Data Protection Regulation 2016/679 of European Parliament and of the Council of 27 April 2016 (the “GDPR”). You agree to promptly assist RealT in complying with any data subject rights request under the GDPR that RealT may receive from any individuals referred to RealT by you. You further agree to promptly assist RealT in complying with any duties to cooperate with supervisory authorities under the GDPR.

  1. Miscellaneous

16.1. You agree that you are an independent contractor, and nothing in this Agreement will create any partnership, joint venture, agency, franchise, sales representative, or employment relationship between you and RealT. You will have no authority to make or accept any offers or representations on our behalf. You will not make any statement, whether on Your Site or any other of Your Site or otherwise, that reasonably would contradict anything in this Section.

16.2. Neither party may assign its rights or obligations under this Agreement to any party, except to a party who obtains all or substantially all of the business or assets of a third party.

16.3. This Agreement shall be governed by and interpreted in accordance with the laws of the State of Florida without regard to the conflicts of laws and principles thereof.

16.4. You may not amend or waive any provision of this Agreement unless in writing and signed by both parties.

16.5. This Agreement represents the entire agreement between us and you, and shall supersede all prior agreements and communications of the parties, oral or written.

16.6. The headings and titles contained in this Agreement are included for convenience only, and shall not limit or otherwise affect the terms of this Agreement.

16.7. If any provision of this Agreement is held to be invalid or unenforceable, that provision shall be eliminated or limited to the minimum extent necessary such that the intent of the parties is effectuated, and the remainder of this agreement shall have full force and effect.