Privacy Policy

Last Updated: December 15, 2025

This Privacy Policy applies specifically to this website (JenniferDeJesus.com) and to Empire Capital Holdings, LLC and its investment offerings, including Empire Investment Club and related real estate syndications and funds. If you're accessing information about Jennifer’s other businesses (Steel City Realty, Steel Abstract, Empire Property Management Group, Empire Property Construction), those operate under separate entities with their own terms and privacy policies. You can find those policies on their respective websites.

This Privacy Policy explains how we collect, use, store, and protect information obtained through this website (the "Site").

Information We Collect

We may collect the following categories of information:

  • Information you provide voluntarily (name, email, phone number, investor accreditation information, etc.).

  • Automatically collected data, such as IP address, browser type, device information, and usage statistics.

  • Information submitted in connection with investment interest, account creation, or subscription documents.

How We Use Information

We use collected information to:

  • Provide access to certain parts of the Site,

  • Evaluate investor eligibility (including accreditation),

  • Communicate with you about investment opportunities, market updates, educational content, and other information related to your interests or subscriptions,

  • Improve Site functionality and user experience,

  • Comply with legal and regulatory obligations.

We do not sell your personal information.

Marketing Communications and Opt-Out

If you've subscribed to receive updates from us, you may opt out at any time by using the unsubscribe link in any email or by contacting us directly. Even if you opt out of marketing communications, we may still send you important account-related or transactional information.

Cookies and Tracking

The Site may use cookies, web beacons, and similar technologies to enhance user experience and analyze traffic. You may disable cookies through your browser settings, but some features may become unavailable.

Sharing of Information

We may share information with:

  • Service providers assisting with website hosting, analytics, or investor-verification processes;

  • Legal, regulatory, or governmental authorities when required;

  • Affiliates involved in the management or administration of offerings.

We do not share personal information with third parties for marketing purposes.

Data Security

We implement commercially reasonable safeguards to protect information from unauthorized access, disclosure, or misuse. However, no data transmission or storage system can be guaranteed 100% secure.

Data Retention

We retain your information for as long as necessary to fulfill the purposes described in this policy or as required by applicable securities laws and regulations. Investor information related to securities offerings is typically retained for at least six years to comply with regulatory requirements.

Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those external sites.

Access and Updates to Your Information

You may request access to, correction of, or deletion of your personal information by contacting us at the address below, subject to applicable law and regulatory obligations.

California Residents

If you are a California resident, you have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the right to request deletion of your personal information, subject to certain exceptions under applicable law. To exercise these rights, contact us using the information below.

International Visitors

This Site is operated in the United States and is intended for U.S. residents. Our investment opportunities are generally available only to accredited investors who are U.S. persons. If you are accessing the Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated.

Children's Privacy

The Site is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors.

Changes to This Policy

We may revise this Privacy Policy at any time. The "Last Updated" date reflects the most recent version. Continued use of the Site constitutes acceptance of the updated policy.

Contact

For privacy-related questions, contact:

Empire Capital Holdings, LLC.
2505 Newburg Road, Easton, PA 18045
610-217-6330
Jen@EmpireCapitalHldgs.com

Bottom line: We collect what we need to run the business and verify investor eligibility. We protect it with standard security practices. We don't sell it. If you want to see, correct, or delete your information, just ask.