Effective Date: July 27, 2026
Last Updated: July 27, 2026
Shuler Group Real Equity LLC, doing business as SGRE Investments (“SGRE,” “we,” “us,” or “our”), respects your privacy.
This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you interact with:
SGRE market briefings and webinar pages
Registration and newsletter forms
Investor qualification surveys
Scheduling and calendar tools
Email, SMS, telephone, and video communications
Other SGRE pages and services that link to this Privacy Policy
Together, these are referred to as the “Services.”
By using the Services or providing personal information, you acknowledge the practices described in this Privacy Policy.
If a specific securities offering, fund, property-owning entity, or investment opportunity provides a separate privacy notice, that notice may also apply. The more specific notice will control if it conflicts with this Privacy Policy.
1. Personal Information We Collect
The information we collect depends on how you interact with SGRE.
A. Contact and Registration Information
We may collect:
Full name
Email address
Telephone number
Mailing address, if voluntarily provided
Communication preferences
Newsletter subscription status
Email and SMS consent selections
Email or SMS opt-out status
The Texas Triangle Market Brief newsletter form is intended to collect an email address for newsletter delivery.
Market briefing registration forms may collect your full name, email address, and telephone number.
B. Investor Qualification Information
The Investor Qualification Survey may collect:
Investor Accreditation Status
Investment Amount Range
Investment Timeline
Full name
Email address
Telephone number
Survey completion status
Qualification or routing classification derived from your answers
Qualification responses are used for preliminary screening and routing. They do not independently verify or certify accredited-investor status.
The public qualification survey is not intended to collect tax returns, bank information, Social Security numbers, payment-card information, or detailed proof of income or net worth. Do not submit those materials through a public website form or survey.
If you later pursue a specific investment, SGRE or the applicable issuer may request additional identification, financial, tax, accreditation, anti-fraud, or subscription information. Additional notices and offering documents may govern that collection.
C. Partial Form and Survey Information
Some forms and surveys may transmit, save, or associate information with a customer relationship management record as you enter it, even if you do not complete the final submission.
This means that starting a form or survey may create or update a record containing information already entered.
Information from an incomplete submission may be used for form functionality, fraud prevention, security, record continuity, or follow-up where permitted by law.
Starting a form or survey without completing it does not, by itself, constitute consent to receive marketing email or SMS communications.
D. Scheduling and Appointment Information
When you schedule or request an Investor Strategy Call, we may collect:
Name
Email address
Telephone number
Selected date and time
Timezone
Calendar and meeting details
Rescheduling or cancellation activity
Appointment status
Notes or information you voluntarily provide
A booking may also create or update a record within SGRE’s customer relationship management system.
E. Communications
When you communicate with SGRE, we may collect:
Email correspondence
SMS messages
Telephone or voicemail information
Responses to automated communications
Communication dates and times
Delivery, bounce, unsubscribe, and opt-out records
Requests for reports, briefings, or other materials
Information voluntarily shared during a strategy call
SGRE does not obtain consent to record a private call solely through this Privacy Policy. If SGRE intends to record a private call or video meeting, it will provide notice and obtain consent as required by applicable law.
F. Website, Device, and Usage Information
When you use the Services, we and our service providers may automatically collect:
Internet Protocol address
Browser and device type
Operating system
Approximate location derived from an IP address
Referring page or source
Pages viewed
Links and buttons selected
Date and time of access
Session and interaction information
Form or survey interaction
Appointment-widget interaction
Video or briefing engagement, where available
Cookie and browser-storage identifiers
UTM parameters and other attribution information
Error, security, and diagnostic information
This information may be used to operate the Services, understand engagement, maintain security, troubleshoot errors, and measure the source of requests.
G. Information From Third Parties
We may receive information from:
Customer relationship management and automation providers
Form, survey, and calendar providers
Email and SMS providers
Video-conferencing providers
Website hosting and content-management providers
Analytics or attribution services, when enabled
Advertising or social-media platforms, when enabled
An applicable investment sponsor, issuer, administrator, or professional advisor
Publicly available sources
Referral partners, with appropriate authorization
Information received from another service may be subject to both this Privacy Policy and the other service’s privacy practices.
2. How We Use Personal Information
We may use personal information to:
Provide requested market briefings, reports, and educational materials
Process newsletter subscriptions
Administer the investor qualification survey
Route inquiries based on qualification responses
Schedule and manage Investor Strategy Calls
Respond to questions and requests
Maintain customer relationship management records
Create or update internal lead or opportunity records
Send requested, operational, educational, or marketing communications
Record and honor consent, unsubscribe, and opt-out preferences
Reclassify or remove a person from an automated communication sequence
Personalize content and communications
Measure page, form, survey, email, and briefing engagement
Preserve source and attribution information
Detect misuse, fraud, or security incidents
Troubleshoot and improve the Services
Comply with legal, regulatory, tax, recordkeeping, and reporting obligations
Establish, exercise, or defend legal claims
Evaluate or complete a business transaction involving SGRE
SGRE will not use investor qualification answers to represent that we have independently verified your accredited-investor status unless a separate verification process has been completed.
3. Email and Newsletter Choices
When you select Subscribe on the Texas Triangle Market Brief form, you request delivery of the newsletter and related email communications.
Registering for a market briefing or requesting a report permits SGRE to send the requested material and communications reasonably related to that request.
Submitting an investor qualification survey does not automatically subscribe you to an unrelated newsletter unless that subscription is separately disclosed and authorized.
You may unsubscribe from marketing emails using the unsubscribe link included in the message.
SGRE may retain a limited suppression record after an unsubscribe request to help ensure that the preference is honored.
4. SMS and Telephone Choices
Where a form presents separate consent options for non-marketing and marketing SMS, SGRE will use your telephone number according to the selections you make.
Marketing SMS consent is optional and is not a condition of requesting information, scheduling a call, purchasing property, goods, or services, or participating in an investment opportunity.
Message frequency may vary. Message and data rates may apply.
You may withdraw SMS consent by replying STOP. You may reply HELP for assistance.
We may retain records of SMS consent and opt-out requests for compliance and suppression purposes.
Providing a telephone number without selecting an applicable consent option does not, by itself, constitute affirmative consent to receive marketing text messages.
5. Cookies and Similar Technologies
SGRE and its service providers may use cookies, pixels, tags, browser storage, and similar technologies to:
Keep pages and embedded tools functioning
Maintain sessions
Remember certain form or browser preferences
Protect against fraud or misuse
Measure website and briefing engagement
Diagnose errors
Preserve referral and attribution information
Support analytics or advertising where enabled
Some embedded forms, surveys, calendars, videos, and other tools may set their own cookies or use browser storage.
You can control many cookies through your browser settings. Disabling cookies may prevent forms, surveys, calendars, or other embedded features from functioning properly.
Some browsers transmit a “Do Not Track” signal. Because there is no single uniform standard for these signals, the Services may not respond to every Do Not Track request.
Where applicable law requires recognition of a universal opt-out preference signal, SGRE will process the signal for covered activity as required by law.
6. How We Disclose Personal Information
We may disclose personal information to the following categories of recipients.
Service Providers
We may use service providers for:
Website hosting and management
Customer relationship management
Forms and surveys
Workflow automation
Email and SMS delivery
Calendar scheduling
Video conferencing
Video hosting
Analytics and attribution
Data storage
Information security
Professional and technical support
These providers may include GoHighLevel or LeadConnector, Microsoft, Zoom, telecommunications providers, website providers, and other vendors supporting SGRE’s operations.
SGRE Personnel and Contractors
Information may be accessible to authorized SGRE personnel, contractors, and professional advisors who need it to perform their responsibilities.
Investment-Related Parties
If you request information about or pursue a specific investment, information may be disclosed to the applicable sponsor, issuer, fund, property-owning entity, administrator, attorney, accountant, verification provider, custodian, lender, or other party involved with that opportunity.
Any additional collection or disclosure may be addressed in the applicable offering documents or separate privacy notice.
Legal and Safety Disclosures
We may disclose information when reasonably necessary to:
Comply with law, regulation, subpoena, or legal process
Respond to a lawful government request
Protect SGRE, investors, users, or other persons
Investigate fraud, misuse, or a security incident
Enforce agreements
Establish, exercise, or defend legal claims
Business Transfers
Information may be disclosed as part of a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, subject to appropriate safeguards and applicable law.
With Your Direction or Consent
We may disclose information when you direct us to do so or provide consent.
7. Sale, Sharing, and Targeted Advertising
SGRE does not sell personal information in exchange for money.
SGRE may use analytics, attribution, or advertising technologies when enabled. Certain disclosures involving online identifiers or browsing activity may be considered “sale,” “sharing,” or processing for targeted advertising under some state privacy laws, even when no money is exchanged.
Where applicable, you may request to opt out of covered sale, sharing, or targeted-advertising activity.
SGRE does not knowingly sell or share the personal information of children.
8. Data Retention
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and for legitimate operational, legal, security, compliance, and recordkeeping needs.
Retention may depend on:
The nature of the relationship
Whether information relates to an investment inquiry or offering
Communication and consent records
Applicable limitation periods
Securities, tax, and regulatory obligations
Fraud-prevention and security needs
Pending disputes or legal claims
Service-provider retention settings
Marketing opt-out and suppression records may be retained after other information is deleted so SGRE can continue honoring the request.
When personal information is no longer reasonably needed, SGRE will delete, anonymize, or securely dispose of it where practicable and legally permitted.
9. Data Security
SGRE uses reasonable administrative, technical, and organizational safeguards designed to protect personal information.
These safeguards may include access controls, authentication, vendor controls, encrypted transmission, system monitoring, and limiting access to people with a legitimate business need.
No website, transmission, or storage system can be guaranteed completely secure. You should not send Social Security numbers, bank credentials, tax returns, payment-card information, or other highly sensitive documents through a public SGRE form or ordinary email unless SGRE provides an authorized secure method.
If a security incident requires notice under applicable law, SGRE will provide legally required notifications.
10. Your Privacy Rights
Depending on where you live and the law that applies, you may have the right to:
Confirm whether SGRE processes your personal information
Request access to personal information
Request correction of inaccurate information
Request deletion of information
Obtain a portable copy of certain information
Withdraw consent for future processing
Opt out of marketing communications
Opt out of covered sale, sharing, or targeted advertising
Limit certain uses of legally defined sensitive information
Appeal the denial of a privacy request
Receive equal service without unlawful discrimination for exercising a privacy right
These rights may be subject to exceptions, verification requirements, and limitations under applicable law.
To submit a privacy request, email:
Use the subject line: Privacy Request
Describe the right you wish to exercise and provide enough information for SGRE to identify the relevant records.
SGRE may request information necessary to verify your identity. Authorized agents may submit requests where permitted by law, subject to verification of their authority.
If SGRE denies an appealable request, you may appeal by replying to the decision with the subject line Privacy Request Appeal.
11. Washington Residents
SGRE is located in Washington and handles personal information in accordance with applicable Washington requirements.
Washington residents may have rights concerning:
Notification following certain data-security breaches
Consumer health data, if collected
Misleading commercial email
Commercial text messages
Unfair or deceptive business practices
Securities-related information and transactions
Nothing in this Privacy Policy limits a right that cannot lawfully be waived.
12. Consumer Health Information
SGRE’s current investor, briefing, newsletter, and scheduling Services are not designed to collect consumer health data.
Do not submit medical conditions, diagnoses, treatment information, medication details, mental-health information, reproductive or sexual-health information, biometric information, or other health information through SGRE’s public forms, surveys, or ordinary email.
If SGRE later offers a service that intentionally collects consumer health data, it will provide any separate notice and obtain any consent required by applicable law.
13. Children’s Privacy
The Services are intended for adults and are not directed to children under 18.
SGRE does not knowingly collect personal information from children through the Services. If we learn that a child provided personal information, we will take reasonable steps to delete it, subject to applicable law.
A parent or guardian who believes a child has provided information may contact SGRE using the information below.
14. International Visitors
SGRE is based in the United States. Personal information may be processed and stored in the United States and other jurisdictions where SGRE’s service providers operate.
Those jurisdictions may have privacy laws that differ from the laws where you live.
If an international privacy law applies, SGRE will rely on an appropriate legal basis for covered processing, which may include consent, steps taken at your request, legitimate business interests, or compliance with legal obligations.
15. Third-Party Websites and Services
The Services may contain links to websites or services SGRE does not control.
This Privacy Policy does not govern an unaffiliated third party’s collection or use of information. Review the third party’s privacy policy before providing information.
The inclusion of a link does not necessarily mean SGRE endorses the third party’s privacy or security practices.
16. Changes to This Privacy Policy
SGRE may update this Privacy Policy when its Services, technology, legal obligations, or data practices change.
The revised policy will be posted with a new “Last Updated” date. Material changes may also be communicated through another reasonable method where required.
17. Contact Information
Questions, concerns, or privacy requests may be sent to:
SGRE Investments
Shuler Group Real Equity LLC
810 NW 61st St
Seattle, Washington 98107
United States
