Effective Date: 11/16/2025
Last Updated: 11/17/2025

1. Introduction

St. James Real Estate Ventures, LLC (“Company,” “we,” “our,” or “us”) is committed to protecting your privacy and complying with applicable U.S. federal and state regulations including, but not limited to, the Securities Exchange Act of 1934, Investment Advisers Act of 1940, Gramm-Leach-Bliley Act (GLBA), and relevant state lending and consumer protection laws.

2. Scope

This Privacy Policy applies to all visitors, clients, investors, and borrowers interacting with our website or services. It aligns with SEC Regulation S-P (Privacy of Consumer Financial Information) and FINRA Rule 3110 (Supervision).

3. Information We Collect

Personal Identifiers: Name, address, email, phone number, DOB
Financial Information: Bank details, investment history, creditworthiness, loan applications
Professional Information: Employment, corporate affiliations, accreditation status
Transactional Records: Advisory engagements, loan agreements, commitment documents
Technical Data: IP address, device identifiers, cookies, analytics

4. How We Use Information

To comply with KYC/AML under the Bank Secrecy Act and USA PATRIOT Act
To evaluate eligibility for loans/investment opportunities under state lending laws
To fulfill reporting obligations under SEC, FINRA, and state regulators
To process transactions according to Regulation Best Interest (Reg BI)

5. Information Sharing

We may share data with:

Regulators: SEC, FINRA, state securities/lending authorities
Service Providers: Auditors, custodians, compliance consultants, IT vendors
Legal Requests: When required by law or regulatory enforcement actions

6. Data Security

We implement safeguards consistent with SEC Regulation S-P and the GLBA Safeguards Rule.

7. Retention

Records are maintained according to SEC Rule 17a-4 and state lending recordkeeping laws.

8. Your Rights

Depending on your state, you may have rights under privacy laws such as the California Consumer Privacy Act (CCPA) to access, correct, or delete your personal data.

9. Contact Us

For privacy inquiries:
F. Anthony Santiago, CEO
Email: asantiago@stjamesre.com