Privacy Policy

Last updated: January 1, 2025

1. Introduction

KickFar Advisory LLC ("KickFar," "we," "us," or "our") operates the Accomplish platform, including our website, mobile applications, and related services (collectively, the "Services"). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Services.

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Services. By using the Services, you consent to the collection and use of information in accordance with this policy.

This Privacy Policy has been prepared in accordance with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable privacy laws.

2. Information We Collect

A. Personal Information You Provide

We may collect personal information that you voluntarily provide to us when you:

• Subscribe to our newsletter or email updates
• Sign up for a Member Level subscription
• Fill out a contact form or inquiry form
• Participate in webinars, events, or surveys
• Communicate with us via email, phone, or chat
• Create an account on our platform
• Make a payment or purchase

This information may include:

• Full name
• Email address
• Phone number
• Mailing address
• Payment information (credit card number, bank account details, PayPal/Venmo account information)
• Investing experience level and areas of interest
• Messages, questions, or feedback you submit
• Any other information you choose to provide

B. Information Collected Automatically

When you access or use our Services, we may automatically collect certain information, including:

• Device Information: Device type, operating system, browser type, unique device identifiers, and mobile network information
• Log Information: IP address, access times, pages viewed, links clicked, and the URLs of sites you visited before and after using our Services
• Usage Information: Features you use, content you view, time spent on pages, and interaction patterns within the Services
• Location Information: General location based on IP address (we do not collect precise GPS location)

C. Information from Third Parties

We may receive information about you from third parties, including:

• Payment processors (e.g., credit card companies, PayPal, Venmo) confirming payment details
• Analytics providers (e.g., Google Analytics)
• Marketing platforms and advertising networks
• Business partners with whom we collaborate

3. How We Use Your Information

We may use the information we collect for the following purposes:

• Provide and improve our Services: To deliver content, process subscriptions, enable account features, and improve your experience
• Communicate with you: To send newsletters, updates, guide chapter releases, webinar invitations, and other information you've opted into receiving
• Process payments: To handle subscription payments, billing, and related transactions
• Respond to inquiries: To answer your questions and provide customer support
• Analyze usage: To understand how users interact with our Services and improve our content, tools, and features
• Personalize your experience: To tailor content, recommendations, and AI-powered insights to your investing interests and experience level
• Ensure security: To detect, prevent, and address fraud, unauthorized access, and other illegal activities
• Comply with legal obligations: To meet requirements under applicable laws and regulations
• Marketing: To send promotional communications about our Services, with your consent where required

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

A. Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

• Payment processing (credit card processing, PayPal, Venmo, bank transfers)
• Email delivery and newsletter distribution
• Web hosting and data storage
• Analytics and performance monitoring
• Customer support platforms

These service providers are contractually obligated to use your information only for the purpose of providing services to us and must protect it in accordance with applicable privacy laws.

B. Legal Requirements

We may disclose your information if required by law, regulation, or legal process (such as a subpoena or court order), or if we believe in good faith that disclosure is necessary to:

• Comply with applicable law or legal process
• Protect and defend our rights or property
• Prevent or investigate fraud or security issues
• Protect the personal safety of any person

C. Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email of any change in ownership or uses of your personal information.

D. With Your Consent

We may share your information with third parties when you have given us your explicit consent to do so.

E. De-Identified or Aggregated Information

We may share de-identified or aggregated information that cannot reasonably be used to identify you, such as general usage statistics, market trends, or demographic insights.

5. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activities. You can learn more about our use of cookies in our Cookie Policy.

Types of Cookies We Use

• Essential Cookies: Required for the operation of our Services (e.g., session management, security)
• Analytics Cookies: Help us understand how visitors interact with our site (e.g., Google Analytics)
• Functionality Cookies: Remember your preferences and settings
• Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling certain cookies may affect the functionality of our Services.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

• Account information: Retained for the duration of your subscription plus 2 years after account closure
• Payment records: Retained for 7 years as required by financial regulations and tax law
• Marketing communications data: Retained until you unsubscribe or request deletion
• Usage and log data: Retained for up to 3 years for analytics and improvement purposes
• Survey and feedback data: Retained for up to 3 years

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data retention schedule.

7. Data Security

We implement reasonable security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (SSL/TLS) and at rest
• Secure payment processing through PCI-DSS compliant providers
• Access controls limiting employee access to personal information on a need-to-know basis
• Regular security assessments and monitoring
• Employee training on data privacy and security practices

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

8. Your Rights Under California Law (CCPA/CPRA)

As a California-based company, we are subject to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). Under these laws, California residents have the following rights:

A. Right to Know and Access

You have the right to request information about the categories and specific pieces of personal information we have collected about you in the past 12 months, including:

• The categories of personal information collected
• The purposes for which the information was collected or sold
• The categories of third parties with whom the information was shared
• The specific pieces of personal information we have collected about you

B. Right to Delete

You have the right to request that we delete your personal information, subject to certain exceptions (such as legal obligations, security purposes, or completing transactions you initiated).

C. Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you.

D. Right to Opt-Out of Sale or Sharing

We do not sell your personal information. However, you have the right to opt out of the "sale" or "sharing" of your personal information as those terms are defined under the CCPA/CPRA. To opt out, please contact us using the information provided below.

E. Right to Limit Use of Sensitive Personal Information

You have the right to limit our use and disclosure of your sensitive personal information to that which is necessary to perform the Services or provide the features you request.

F. Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. This means we will not deny, change the terms of, or charge you more for our Services because you exercised your privacy rights.

G. Right to Authorized Agent

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's authority and your identity.

9. How to Exercise Your Rights

To exercise any of the rights described above, please contact us by:

• Email: privacy@kickfar.com
• Phone: (858) 255-1860
• Mail: KickFar Advisory LLC, 1276 Auto Park Way, Suite D132, Escondido, CA 92029

We will respond to your request within 45 days, as required by California law. If we need more time, we will notify you of the reason and estimated time of completion. We may verify your identity before processing your request by asking for information sufficient to match you with the information we maintain.

10. CCPA Disclosures

In the preceding 12 months, KickFar Advisory has collected the following categories of personal information:

We do not sell personal information. "Shared" refers to disclosure to service providers for business purposes only.

11. Financial Information

We collect and process payment information (such as credit card numbers, bank account details, and digital payment account information) solely for the purpose of processing your subscription payments. This information is handled by PCI-DSS compliant third-party payment processors and is not stored on our servers beyond what is necessary to process transactions and provide customer support.

12. Email Communications

If you subscribe to our email communications, we will send you newsletters, guide updates, market insights, and other information related to real estate investing. You can opt out of marketing emails at any time by:

• Clicking the "Unsubscribe" link at the bottom of any marketing email
• Contacting us at privacy@kickfar.com
• Updating your email preferences in your account settings

Please note that even if you opt out of marketing emails, we may still send you transactional or service-related communications (such as payment confirmations or account updates) as necessary to provide our Services.

13. Third-Party Links

Our Services may contain links to third-party websites, applications, or services that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you visit or use.

14. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a child under 18, please contact us at privacy@kickfar.com.

15. California Shine the Light Law

Under California Civil Code Section 1798.83, California residents have the right to request certain information about how we share personal information with third parties for their direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes. To make a request, please contact us at privacy@kickfar.com.

16. Do Not Track Signals

Some browsers offer a "Do Not Track" (DNT) feature that signals to websites that you do not want to be tracked. Because there is no industry consensus on how to respond to DNT signals, our Services do not currently respond to DNT signals. You can manage your tracking preferences through our Cookie Policy and your browser settings.

17. International Users

Our Services are primarily intended for users located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. By using our Services, you consent to this transfer.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will:

• Update the "Last updated" date at the top of this page
• Post the updated Privacy Policy on our website
• Send an email notification for material changes (to the email address on file)

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

19. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us: