Privacy Policy

Last Updated: September 4, 2025

I. ABOUT OUR PRIVACY NOTICE

This Privacy Notice (the “Notice”) describes the practices in connection with information that Steadfast Investment Management, LLC, and it affiliates and related companies (collectively, “Steadfast Direct,” “we,” “us,” or “our”) may receive and collect from you through:

The websites that we control, including www.steadfast-direct.com (collectively, the “Websites”).

Software applications made available by us for use on or through computers and mobile devices (collectively, the “Apps”).
Any social media pages that we control (collectively, the “Social Media Pages”).
Email messages or other electronic communications (telephone calls, voice mails, etc.) that we send to or receive from you.
In-person communications that we have with you.

Collectively, we refer to the above-referenced sources that we may receive and collect information from you as the “Services.”

Steadfast Direct respects your privacy and is committed to ensuring the protection of your personal information. Through the Services, Steadfast Direct may receive and collect certain personal information about you in connection with providing those services. Steadfast Direct strives to protect the privacy of your personal information as much as reasonably possible while still allowing us to use that personal information to provide you services. This Notice does not alter or change any written agreement that you may have with Steadfast Direct or any entity with which you have an investment.

Our privacy practices and the rights and choices you may have with respect to your personal information may vary among the states in which we operate to comply with legal requirements. We have developed this Notice with the recognition that applicable laws regarding privacy and personally identifying information are evolving and changing rapidly. Accordingly, this Notice may change from time to time, and Steadfast Direct expressly reserves the right to modify the terms of the Notice at any time and to our reasonable discretion. We will identify the date this Notice was last modified at the top of this Notice.

II. ACCEPTANCE OF OUR PRIVACY NOTICE

By using or accessing the Services, you signify your acceptance of this Notice and acknowledge your awareness of its terms. If you do not accept this Notice, you are not authorized to use or access the Services and must immediately discontinue using or accessing them.

III. THIRD-PARTY LINKS

When using the Services, you may have the opportunity to link to websites or interact with features from third-parties that operate independently from Steadfast Direct. This Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third-parties, including any third-party operating any website or service to which the Services link. We have no control over and are not responsible for the privacy practices of these third-parties or the content provided thereon. We recommend that you familiarize yourself with the privacy practices of these third-parties. The inclusion of a link on the Services does not imply a recommendation or endorsement of the linked site or service by Steadfast Direct.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Apple, Google, Microsoft, or any other app developer, app provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information (as defined herein) that you disclose to other organizations through or in connection with the Websites, Apps, or Social Media Pages.

IV. PERSONAL INFORMATION

When you use or access the Services, Steadfast Direct receives and collects certain personal information for lawful purposes in the operations and conduct of our business. The type of personal information we receive and collect from you will vary and depend upon what we may need to provide you with the product or service that you are interested in. For example, a prospective investor, current investor, and individual only browsing the Services will not all provide the same personal information, but rather only the personal information that we may need to provide them with the product or service that they are interested in.

“Personal information” is information that identifies you as an individual or relates to an identifiable individual. The Services receive and collect Personal Information, including:

Personal contact information (name, nickname, gender, mailing address, email address, phone number).
Postal address (including billing and shipping addresses).
Business information (office location, business contact information, department, job title/ description, professional biography).
Payment information (bank account, credit card, any and other payment information).
Log-in credentials (username, password).
IP address (we may also derive your approximate location from your IP address).
Any other information you or other Steadfast Direct customers may upload or enter into the Services.

Certain of the Services may receive and collect additional Personal Information specific to the service. For example:

We may collect additional information when verifying accredited investor status, such as annual income, proof of income, net worth, tax returns, Social Security Number, date of birth, professional certifications, and co-investor information.
We may collect additional information when your accredited investor status has been verified and you make an investment, such as banking account information, retirement account information, or brokerage/investment account information.

Collection of Personal Information

We need to receive and collect Personal Information to provide you with the Services. If you do not provide us with the information requested, we may not be able to provide the Services to you. If you disclose any Personal Information relating to other people (spouse, children) to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Notice.

We receive and collect Personal Information in a variety of ways, including:

From You or With Your Permission

Steadfast Direct receives and collects Personal Information from and about you when you provide it to us directly, when we request it from you, and when you give us permission to get it from a third-party. We may collect Personal Information from you or with your permission when you use the Services or communicate with us in person to:

Verify accredited investor status.
Inquire about, apply or register for, or hold an investment.
Contact or communicate with us through the Services.
Use our chatbot.
Register for and use an online investor account.
Make payments for an investment.
Contact the investor hotline.
Use our investor relationship management system or database.
Meet or communicate with us in person or offline.
Authorize social media companies, search engines, and third-party company websites to share your personal information with us.
Send us communications through email, U.S. mail, voice mail, or other delivery service (such as UPS, Federal Express, etc.).

From Our Service Providers

Steadfast Direct retains service providers to assist us with our business and providing the Services, including:

Providing access to investment offerings.
Processing, managing, and reporting on investments.
Processing payments for investments.
Maintaining our investor portal, investor hotline, and other customer service tools.
Hosting our Websites, Apps, and Social Media Pages.
Marketing the Services.

We may obtain Personal Information about you when you provide it to our service provider directly, when our service provider requests it from you, and when you give us permission to get it from our service provider. For most, if not all, of these services, you will move away from www.steadfast-direct.com when engaging in those services, and those websites will have their own privacy notice unique to those websites. This Notice does not apply to those websites, and we recommend that you familiarize yourself with their privacy notice before using them.

Use of Personal Information

Steadfast Direct uses the Personal Information that we receive and collect to help us provide, operate, improve, understand, customize, support, and market the Services. We may also use the Personal Information that we receive and collect for other purposes where permitted by law, including:

Authenticating you or your device when using our investor portal, investor hotline, and other customer service tools.
Verifying your identity.
Managing your investments.
Processing your application to invest.
Verifying your eligibility for investments.
Carrying out our obligations and enforcing our rights arising from contracts entered into with you.
Communicating with you and responding to your inquiries, comments, and suggestions.
Providing you with, customizing, and improving our products and Services.
Carry out the specific purpose for which you provided us with the Personal Information.
Administering and processing payments.
Completing tasks relating to your transactions and interactions with Steadfast Direct.
Marketing our products and Services.
Authenticating use and detecting potential fraud.
Complying with legal requirements and protecting against liability.
Anonymizing and aggregating information for analytics and reporting.
Marketing, promoting, and driving engagement with the Services.
For any other purpose with your consent.

Sharing and Disclosure of Personal Information

Except as set forth in this Notice, Steadfast Direct does not sell, share, or disclose the Personal Information that we have received and collected from you to third-parties without your consent. To provide, operate, improve, understand, customize, support, and market the Services, we may share and disclose Personal Information to the following:

Affiliated or Subsidiary Companies

We may share and disclose Personal Information with our affiliated or subsidiary companies who require access to Personal Information for legitimate business purposes related to your investment or to process any application, request, inquiry, or other information or Personal Information you submit to us through the Services.

Service Providers and Business Partners

Steadfast Direct retains third-party service providers to assist us with our business and providing the Services. We may share and disclose your Personal Information with service providers to help us operate, provide, improve, understand, customize, support, and market our products and Services. These service providers perform services: (i) on our behalf; (ii) on behalf of the owner of one of our communities and who may use this Personal Information for their own purposes, including sending advertisements to you; or (iii) on behalf of entities related to your investments. This includes, without limitation, service providers that verify investor eligibility, process investments, send or receive communications, process payments, provide marketing assistance, monitor compliance with applicable law, or create, host, and/or provide customer service tools on our behalf. In most instances, these service providers are required to use the Personal Information only to provide their service to us and are prohibited from using it for their own purposes.

Legal and Safety Reasons

Steadfast Direct respects and complies with our legal obligations and may share and disclose Personal Information that we have received and collected about you as required by law. We may share and disclose such information in response to or cooperating with law enforcement authorities, government inquiries or audits, and legal process (such as a court order or subpoena).

We may share and disclose Personal Information that we have received and collected about you: (i) to establish or exercise our legal rights or defend against legal claims; (ii) to detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; and/or (iii) to protect our or others’ rights, property, or safety.

We may share and disclose Personal Information that we have received and collected about you to prevent injury or other harm to any person or entity, including you and members of the general public.

Business Transactions

Steadfast Direct may share and disclose Personal Information that we have received and collected about you with the relevant participants or successor in business transactions or potential business transactions, including any reorganization, merger, acquisition, consolidation, dissolution, sale, or other transfer of all or any portion of our business.

Protection and Retention of Personal Information

Steadfast Direct takes commercially reasonable measures to secure and protect your Personal Information from unauthorized access, use, and disclosure. We use industry-standard, appropriate, and feasible physical, technical, organizational, and administrative safeguards and security measures based on the type of Personal Information that we receive and collect and how we are using this information. We limit access to Personal Information to employees who we believe reasonably need to receive such information to provide our services or to do their jobs, and we take the precautions we deem reasonable to protect the security of your Personal Information.

Please be aware, however, that no method of transmitting data over the Internet or storing data on software, hardware, or networks is completely secure. We cannot guarantee the complete security of any Personal Information that you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss, or inadvertent disclosure of your Personal Information. You therefore disclose Personal Information to us at your own risk.

Steadfast Direct generally retains your Personal Information and our records only as long as necessary and required for or the business purposes for which we obtained it, for reasonable business purposes, or to satisfy legal requirements.

V. NON-PERSONAL INFORMATION

When you use or access the Services, Steadfast Direct receives and collects certain non-personal information for lawful purposes in the operations and conduct of our business. We may use and disclose non-personal information for any purpose, except where we are required to do otherwise under applicable law. Non-personal information helps us improve and personalize your experience on our Websites, Apps, and Social Media Pages, defend against and detect fraudulent activity or cyberattacks, and maintain the security of our services.

“Non-Personal Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Non-Personal Information includes data and information that is aggregated or de-identified and thus not linked to personal contact information. Non-Personal Information does not personally identify the individual to whom the information or data collected relates. The Services receive and collect Non-Personal Information, including:

Browser and device information.
App usage data.
Information collected through cookies, pixel tags and other technologies.
Demographic information and other information provided by you that does not reveal your specific identity.
Information that has been aggregated in a manner such that it no longer reveals your specific identity.

Collection of Non-Personal Information

When you use or access the Services, Steadfast Direct receives and collects Non-Personal Information in a variety of ways including:

IP Address

An Internet Protocol address (“IP address”) is a numerical label assigned to each device connected to a computer network that uses the Internet Protocol for communication. An IP address serves two main functions: host or network interface identification and location addressing. As permitted by law, Steadfast Direct collects aggregate user information sitewide, including IP addresses, for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for users, and auditing the use of our site.

Absent the potential need to defend against or investigate fraudulent activity, cyberattacks, or criminal conduct, we do not link IP addresses to anything personally identifiable. This means that a user’s session may be tracked, but the user will be and remain anonymous.

Your Browser or Device

Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the online services (such as the app) you are using. We use this information to ensure that the Websites, Apps, and Social Media Pages function properly.

Your Use of the Apps

When you download and use the Apps, we may track and collect usage data, such as the date and time the Apps on your device access our servers and what information and files have been downloaded from the Apps based on your device number.

Cookies and Similar Data Collection Technologies

Non-personal information may be collected in a variety of ways, including data collection technologies. Data collection technologies refer to, among other things, cookies, web beacons, pixels, gifs, tags, and other technologies that collect information in similar ways. Data collection technologies help us to improve your experience on the Websites, Apps, and Social Media Pages by providing us with non-personal information for compiling statistics about their use and access and analyzing technical and navigational information about them.

A cookie is a small text file that is sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (Internet location) from which the cookie originated, the “lifetime” of the cookie (when it expires), and a randomly generated unique number or some other identifier. A cookie may also contain information about your computer, such as user settings, browsing history, and activities conducted while using this web site. A cookie cannot be read by any website other than the one that set up the cookie.

Data collection technologies enable us to recognize the information that you have consented to give to us and to help us provide you with better Websites, Apps, and Social Media Pages by enabling us to monitor the pages that you find useful. Other than the data and information that you choose to share with us, data collection technologies do not provide us with access to your computer or any personally identifiable information about you. We do not use data collection technologies to examine your web surfing behavior before or after leaving the Websites, Apps, and Social Media Pages.

By showing how and when users use the Websites, Apps, and Social Media Pages, data collection technologies help us see which areas are popular and which are not popular. Many improvements and updates to the Websites, Apps, and Social Media Pages are based on such data as the total number of visitors and pages viewed. This information is most easily tracked with cookies. We use the information only to provide services better tailored to your needs and for the protection of our website and users from potential harm.

By using or accessing the Websites, Apps, and Social Media Pages, you agree to our use of data collection technologies in the following ways, as well as other similar purposes:

Analytics.
Marketing.
Preserving your preferences.
Personalizing your experience.
Understanding where our traffic is originating.
Ensuring the security and availability of our Websites, Apps, and Social Media Pages.

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Websites, Apps, and Social Media Pages. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

Third-Party Analytics Services

Our Websites, Apps, and Social Media Pages may use analytics services provided by third parties. These analytics services use cookies and other data collection technologies to collect and store information about your use. Analytics services may also offer certain advertising features that we may utilize.

We use Google Analytics to analyze browsing activity, to better understand the behavior of visitors to our Websites, Apps, and Social Media Pages, and for certain advertising features that it offers. Google Analytics uses cookies and other data collection technologies to gather statistical data and help analyze how users use the Websites, Apps, and Social Media Pages. Google will use this information to monitor your use, compile reports on activity, and provide other services related to activity and Internet usage. Google may transfer this information to third parties where required by law, or where such third parties process information on Google’s behalf.

For more information on Google’s privacy policy with respect to Google Analytics, please visit https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008. You can opt-out from being tracked by Google Analytics by installing the Google Analytics Opt-Out Browser Add-On at https://tools.google.com/dlpage/gaoptout. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by changing the ad settings https://www.google.com/settings/ads.

Uses and Disclosures of Non-Personal Information

We may use and disclose Non-Personal Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Non-Personal Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Notice. In some instances, we may combine Non-Personal Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

VI. PRIVACY OF MINORS

The Services are not directed at or intended to be used by minors. We do not knowingly collect or maintain personal information from or about minors, unless required by law and except for certain limited personal information that may be provided by a parent or guardian in connection with their housing or application for housing. For example, we maintain records regarding the identities of those who reside in an apartment. If you provide personal information to us, you represent and warrant to Steadfast Direct that you are not a minor. If we discover that we have collected personal information from a minor, we will take reasonable measures to delete such information from our systems. If you are a parent or guardian and believe that your minor may have provided personally identifiable information through the Services, please contact us by using the information in the “Questions or Comments” section below.

VII. YOUR CHOICES, QUESTIONS, OR COMMENTS

You may update or correct your Personal Information by logging into your account or contacting us by any of the means set forth below. You may also unsubscribe from marketing emails, but you will continue to receive administrative or transactional messages relating to your account or investment, such as investment confirmations, account statements, or required reports.

Steadfast Direct welcomes your questions about this Notice and the ways in which we collect and use your personal information. Please contact us by using the information below, and we will respond to you as soon as reasonably possible.

By Mail: Steadfast Companies

Attn: Privacy Notice

18100 Von Karman Avenue, Suite 500

Irvine, CA 92612

By Email: Privacy@Steadfastcompanies.com

By Phone: (877) 789-7264

VIII. SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

The contents of this section supplement the Notice set forth above and apply solely to California residents. If there are any conflicts between this section and any other provision of this Notice and you are a California resident, the portion that is more protective of your personal information shall control.

California residents are afforded certain rights regarding their personal information under the California Consumer Privacy Act of 2018 (“CCPA”). For purposes of this section, “personal information” has the meaning given to it in the CCPA, but it does not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA’s scope.

Your CCPA Rights

Right to Know

You have the right to request a description of the following personal information that we have collected about you during the past twelve (12) months:

Categories of personal information we have collected about you.
Categories of sources from which that personal information was collected.
Purpose for collecting or selling your personal information.
Categories of third-parties with whom we have shared your personal information.

If we have disclosed your personal information for a business purpose over the past twelve (12) months, we will identify the categories of personal information shared with each category of third-party recipient.

Right to Access

You have the right to request specific pieces of personal information that we have collected about you during the past twelve (12) months.

Right to Delete

You have the right to request that we delete the personal information that we have collected from you.

This right is not absolute and is subject to certain exceptions. For example, we may deny your deletion request if we need your personal information for a reason related to:

Completing a transaction, providing goods or services requested by you, or otherwise performing a contract with you.
Detecting and resolving issues related to security or functionality.
Complying with legal obligations and exercising or defending legal claims.
Conducting research in the public interest.
Using deidentified or aggregated consumer information.
Exercising free speech or ensuring another’s exercise of free speech.
Using the information for internal purposes that you might expect based on our relationship with you.

Right to Opt-Out

Except as set forth in this Notice, Steadfast does not sell, share, or disclose the personal information that we have collected and maintained about you to third-parties without your consent. The CCPA, however, also gives you the right to request that we do not sell (as defined by the CCPA) your personal information and refrain from doing so in the future by visiting the following link: Do Not Sell My Info

Exercising Your CCPA Rights

To protect the privacy of your personal information, Steadfast is required to verify your identity and California residency to process your request under the CCPA. We cannot process your request if you do not provide us with sufficient detail to allow us to verify your identity and understand and respond to the request. A California resident can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have written authorization confirming that authority.

To exercise your CCPA rights, you must send us a request that:

Provides sufficient information to allow us to verify that you are the person about whom we have collected the personal information; and
Describes your request in sufficient detail that allows us to properly understand, evaluate, and respond to it.

Each request that meets these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will work to complete your request within forty-five (45) days of our receipt of a Valid Request. We will not charge you a fee for making a Valid Request.

All personal information provided to us in connection with a Valid Request will be used only to verify you and complete your request. Please do not provide your complete Social Security Number in any electronic communication to us when exercising your CCPA rights.

You may submit a Valid Request using either one of the following methods:

By Email: CCPA@Steadfastcompanies.com

By Toll-Free Telephone Number: (877) 789-7264

Right to Non-discrimination

You have the right not to be discriminated against for exercising any of your rights under the CCPA. You thus will not be denied goods or services, charged different prices, or provided with a different level or quality of service by exercising an of your rights under the CCPA. Steadfast does not offer any financial incentive or price or service difference in exchange for the retention or sale of your personal information.