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Privacy Policy

Last updated: January 1, 2026

1. Introduction

This Privacy Policy explains how Fremont Developers LLC ("Fremont Developers," "we," "us," or "our") collects, uses, and shares personal information when you visit fremontdevelopers.com (the "Site") or interact with us by email, phone, or form submission. Fremont Developers is a Bay Area real estate development and investment firm headquartered in Newark, California. This policy applies to the Site and to all affiliated operating entities including SPSD Developers LLC, Golden Years Living LLC, Golden Years Chowchilla LLC, Tranquil Path LLC, and YKRK.

2. Information We Collect

We collect information in the following ways:

  • Contact forms. When you submit a form on our Site — for example, a leasing inquiry, an investor interest form, or a senior living tour request — we collect the information you provide (typically name, email, phone number, and any context you share in a message field).
  • Investor inquiries. If you request access to offering documents, we may collect additional information needed to verify accredited investor status (such as income or net worth attestations, supporting tax or brokerage documentation, or letters from your CPA, attorney, or broker-dealer).
  • Website analytics. We use standard analytics tools to understand how visitors use the Site. This includes aggregated and pseudonymized data such as pages visited, referral source, browser type, and approximate location (at the city or regional level).
  • Cookies. We use cookies and similar technologies for essential Site functions and analytics. See Section 7.

3. How We Use Your Information

We use your information to:

  • Respond to inquiries about our projects, homes, and investment offerings.
  • Send offering documents (such as a Private Placement Memorandum) to verified accredited investors.
  • Provide tour information and follow-up materials for families considering Velora Senior Living.
  • Send optional newsletter content if you have subscribed.
  • Improve the Site's content, design, and performance.
  • Meet recordkeeping and compliance obligations, including those imposed by the SEC, California Department of Real Estate, and California Department of Social Services.

4. How We Share Information

We share personal information only in limited, specific circumstances:

  • Outside counsel and advisors. We may share information with our securities counsel, real estate counsel, tax advisors, and auditors as needed to prepare or review offerings and communications.
  • Accreditation verification. If you request offering documents under Regulation D Rule 506(c), we collect attestation materials and supporting documentation directly to verify accredited status. If you choose to provide a verification letter from your CPA, attorney, or broker-dealer, we may verify the letter with the issuing professional. We do not share your information with third-party verification services.
  • Service providers. We use vendors for email delivery, form processing, CRM, and analytics. These vendors are bound by confidentiality obligations and process data only on our behalf.
  • Legal obligations. We may disclose information if required by law, subpoena, or court order, or to protect the rights, property, or safety of Fremont Developers, our residents, or the public.

We do not sell personal information as "sale" is defined under the California Consumer Privacy Act (CCPA) or California Privacy Rights Act (CPRA). We do not share personal information for cross-context behavioral advertising.

5. Data Retention

We keep personal information only as long as we need it. General inquiry data is typically retained for up to two years. Investment-related records, including subscription documents, accreditation verification, and investor communications, are retained for at least seven years, consistent with SEC and state recordkeeping requirements. Senior living tour and resident inquiry data is retained according to California Department of Social Services guidelines.

6. Your Rights

If you are a California resident, the California Privacy Rights Act (CPRA) gives you the right to:

  • Access — request a copy of the personal information we hold about you.
  • Delete — request deletion of personal information, subject to exceptions (for example, records we must retain for SEC compliance).
  • Correct — request correction of inaccurate information.
  • Opt out — opt out of any "sale" or "share" of your personal information (we do not sell or share personal information, but you may still exercise this right).
  • Limit use of sensitive information — restrict our use of sensitive personal information to necessary business purposes.

To exercise any of these rights, email privacy@fremontdevelopers.com. We will respond within 45 days. We will not discriminate against you for exercising a privacy right.

7. Cookies and Analytics

We use a small number of cookies and similar technologies, including Google Analytics (or a comparable provider), to understand Site usage. You can disable cookies in your browser settings or install a browser extension such as the Google Analytics Opt-out to prevent data collection. Essential cookies — those required for the Site to function — may remain active even when optional cookies are disabled.

8. Children's Privacy

This Site is not directed at children under 13, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us at privacy@fremontdevelopers.com and we will delete the information promptly.

9. Security

We take reasonable administrative, technical, and physical measures to protect personal information, including access controls, encryption in transit, and vendor diligence. No system is perfectly secure, and we cannot guarantee absolute protection against unauthorized access. If we become aware of a security incident affecting your personal information, we will notify you consistent with applicable law.

10. Contact

For questions about this Privacy Policy, to exercise a privacy right, or to report a concern:

Email: privacy@fremontdevelopers.com
Mail: Fremont Developers LLC, Attn: Privacy, Newark, California
Phone: (510) 555-0100

This policy may be updated from time to time. Material changes will be communicated via the Site or by email to registered users. Your continued use of the Site after an update constitutes acceptance of the revised policy.