Last Revised: 11 September 2017

This Privacy Policy explains how MREN, Inc. (“us”, “we” or “ our”) collects and uses certain information that you provide through our website located at website at, its successor website, and any of its subpages, subdomains or desktop and mobile versions, including any content, materials, software, information, data, features, functionality and services made available therein (the “Website”). By making available Personal Information (as defined in Section 1.1) or Other Information (as defined in Section ‎3.1) to us, you acknowledge that you have read and understand this Privacy Policy and that you consent to its terms.

Please read this Privacy Policy carefully to understand how we process your information. If you do not agree with the practices and procedures described in this Privacy Policy, please discontinue using the Website.


1.1 Information We May Collect. Depending on the circumstances, we may collect and hold a range of different information about you,
including information that identifies you as an individual or relates to an identifiable person, such as your name and contact details (“ Personal Information”).

1.2 How We Collect Personal Information. We may collect your Personal Information in a number of ways, including:

(A) Directly from you, such as where you provide information to us when you visit the Website, complete an application form, register an account on the
Website or contact us with a query or request. Personal Information may also be collected if you make that Personal Information available when you publish
or make your Personal Information via the Website, such as when you fill out a user profile, message or communicate with others, post or share a real
estate listing or teaser or when you post or share any Personal Information as part of the transactions in which you participate via the Website (such as,
part of the due diligence process in which you participate).

(B) From other third parties who share your Personal Information when they use the Website, such as if they include your Personal Information when they
message or communicate with others via the Website and when they post or share a real estate listing or teaser.

1.3 How We May Use Personal Information. We may use Personal Information:

(A) To present the Website to you and others, including the content, features, applications, and functionalities made available via the Website.

(B) To provide you with notices about your account and to communicate with you about the availability of the Website, security and other Website-related
issues, and to send administrative information to you, for example, information regarding the Website and changes to our terms, conditions, and policies.

(C) To fulfill our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

(D) To conduct analysis, research and development for the improvement of the Website and our other products and services, to provide you and others with an
improved website and services and to customize your experience with the Website (such as by making it more relevant and useful to you and to refine our
Website search services).

(E) For our internal business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new websites, products and services,
enhancing, improving or modifying our services, identifying usage trends, conducting studies and analyzing the results of studies, and operating and
expanding our business activities.

(F) If we reasonably believe it is necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply
with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country
of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights,
privacy, safety or property, and/or that of our affiliates, you or others; or (vii) to allow us to pursue available remedies or limit the damages that we
may incur or suffer.

(G) In any other way we may describe when you provide the Personal Information.

(H) For any other purpose with your consent.

1.4 How Personal Information May Be Disclosed. Your Personal Information may be disclosed:

(A) To our employees, affiliates or third parties who provide services to us, including service providers and contractors that assist us with the purposes
for which we use your Personal Information. These services may include customer enquiries, mailing operations, email and marketing services, map services,
billing and payment processing functions, debt-recovery functions, data analysis, auditing, web hosting, data entry and services provided by professionals,
such as accountants, lawyers, business advisors and consultants.

(B) To third parties to facilitate or implement a transfer/sale of all or part of our assets or business, or in the event of any reorganization, merger,
sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any
bankruptcy or similar proceedings).

(C) To your authorized representatives or advisers, or when you ask us to do so.

(D) To third parties who assist us to manage or develop our business and corporate strategies and functions, including our corporate risk or funding

(E) If we reasonably believe it is necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply
with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country
of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights,
privacy, safety or property, and/or that of our affiliates, you or others; and (vii) to allow us to pursue available remedies or limit the damages that we
may sustain. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

1.5 Your Disclosure of Personal Information.

(A) As the Website is intended to provide you with a platform to communicate, collaborate and transact with other principal buyers/sellers and professional
service providers of such buyers/sellers, you acknowledge and agree that when you communicate with others via the Website, the recipient may see your name,
email address, user profile and any other Personal Information you made available to that recipient.

(B) You are responsible for any information you post on the Website, including via its virtual data rooms, and this information will be accessible to
registered users of the Website of the relevant virtual data room. If you share information such as by posting information in the virtual data room, your
user profile or a real estate listing, you should be aware that any information you choose to disclose may be read, collected, and used by other registered
users. We are not responsible for the information you choose to disclose via the Website.


2.1 We may also use your Personal Information so that we can promote and market the Website and any other products, services and special offers that we
think will be of interest to you. This marketing will be carried out by email using the email address you have provided us, and may continue after you
cease acquiring any products or services from us until you opt-out. You may opt-out on a going-forward basis, by clicking on the “unsubscribe”
link (or similar) provided in the relevant marketing email. We will try to comply with your request as soon as reasonably practicable.

2.2 Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative and
Website-related messages, and you cannot opt-out from receiving those messages.


3.1 Other Information We May Collect.
Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:

(A) Browser and device information;

(B) Internet Protocol (“IP”) address;

(C) Pages visited;

(D) Average time spent on the Website;

(E) Information collected through cookies and other technologies; and

(F) Aggregated information.

3.2 How We May Collect Other Information. We may collect Other Information in a variety of ways, including:

(A) Through 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 Macintosh), screen resolution, operating system name and version, device manufacturer and
model, language, and Internet browser type and version. We use this information to ensure that the Website and its services function properly.

(B) Through your use of the Website. When you visit the Website, we may track and collect Website usage data, such as your search history.

(C) Using cookies and other technologies.

(1) Cookies are pieces of information stored directly on the computer that you are using. Cookies and other technologies such as pixel tags and web beacons
allow us to collect information, such as browser type, time spent on the Website, pages visited, language preferences, and other website traffic data. We
use the information for security purposes, to facilitate navigation, and display information more effectively. We can recognize your computer to assist
your use of the Website.

(2) Many web browsers allow you to control the use of most cookies through their browser settings. To learn more about cookies, including information on
what cookies have been set on your computer and how cookies can be managed and deleted, visit

(3) Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you access or use the Website. Other
technologies we may use may not be blocked by your browser or other interface settings. By accessing or using the Website you consent to us using cookies
and other technologies in accordance with this Privacy Policy. In the event you refuse to accept cookies, some areas of the Website may not function
properly or may not be accessible.

(D) IP Address. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your
Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Website,
along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many
websites, applications and other services. We may use IP Addresses for purposes such as calculating usage levels of the Website, helping diagnose server
problems, and administering the Website and its associated services.

(E) From you. Information, such as your preferred means of communication, is collected when you voluntarily provide this information.

(F) By aggregating information. Aggregated Personal Information does not personally identify you or any other user of the Website (for
example, we may aggregate Personal Information to calculate the percentage of our users who have a particular zip code).

3.3 How We May Use and Disclose Other Information.

(A) We may use and disclose Other Information for any lawful purpose, such as for research, reporting and analytic purposes and to improve the Website.

(B) If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use
and disclose Personal Information.

(C) In some instances, we may combine Other Information with Personal Information (such as by combining your name with the state in which you live). If we
combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.


4.1 This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including our
other Website users or any third party operating any site or service to which the Website links to or is linked from. The inclusion of a link on the
Website does not imply endorsement of the linked site or service by us or by our affiliates.

4.2 Our Website may contain third-party advertisements or offers that are complementary to your use of the Website. If you choose to use these separate
products or services, disclose information to the providers, and/or grant them permission to collect information about you, then their use of your
information is governed by their privacy policy. You should evaluate their practices before deciding to use their services.


5.1 We seek to use reasonable organizational, technical and administrative measures to protect Personal Information that we maintain within our
organization. Unfortunately, no data transmission or storage system can be guaranteed to be fully secure.

5.2 The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Website, you are
responsible for keeping this password confidential. You should not share your password with anyone.

5.3 If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have
with us has been compromised), please immediately notify us of the problem by contacting us in accordance with Section ‎11 (Contacting Us) below.


6.1 You may request access to any Personal Information we hold about you at any time by contacting us in accordance with Section ‎11 (Contacting Us)
below. Where we hold Personal Information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by
mailing or emailing it to you). If you make an access request, we may ask you to verify your identity.

6.2 There may be instances where we cannot grant you access to the Personal Information we hold. For example, we may need to refuse access if granting
access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you reasons for any

6.3 If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, then you should first try to update the information
using your online account settings, such as by editing your profile, deleting content that you have posted or by closing account. You may also request that
we update it by contacting us in accordance with Section ‎11 (Contacting Us) below. We will consider if the information requires updating. If we do
not agree that there are grounds for updating it, then we will add a note to the Personal Information stating that you disagree with it.

6.4 Information you have shared with others via the Website or that others have copied may also remain visible after you have closed your account or
deleted the information from your own user profile

6.5 We may retain your information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet
regulatory requirements, resolve disputes between users of the Website, prevent fraud and abuse, or enforce this Privacy Policy and our Terms of Service.

7. Your California Privacy Rights.

7.1 Accessing Your Information. California Civil Code section 1798.83 permits users of the Website that are California residents to
request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Requests may be made
only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct
marketing purposes.

7.2 Do Not Track Disclosure. As we do not track you across the web, we do not respond to “Do Not Track” signals. Except as
otherwise specified in this Privacy Policy, we do not enable third parties to collect Personal Information about your online activities over time and
across third-party websites when you use our Website.


8.1 The services are not directed to individuals under the age of 18, and we request that these individuals do not provide Personal Information through the
Website or its associated services.


9.1 The Website is controlled and operated by us from the United States, and is not intended to subject us to the laws or jurisdiction of any state,
country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or
in which we engage service providers (such as, but not limited to, the United States), and by using the Website you consent to the transfer of information
to countries outside of your country of residence, which may have different data protection rules.


10.1 We may change this Privacy Policy by notifying you of such changes by any reasonable means, including by posting a revised Privacy Policy through the
Website, or, if we think the changes will be materially detrimental to you and we have your contact details, then by emailing you via the contact details
you provided us.

10.2 Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website. Your use of the Website following any
changes to this Privacy Policy will constitute your acceptance of such changes. The “Last Revised” legend above indicates when this
Privacy Policy was last changed.


11.1 If you have any questions about this Privacy Policy or if you have any privacy related concerns, please contact us via:

Christopher Hays

Privacy Officer

MREN, Inc.

12335 World Trade Drive, Suite 1A

San Diego, CA 92128

Email address:

Phone: 858-329-9291 during the hours of 8:00 AM to 5:00PM Pacific time, Monday to Friday.

11.2 Please note that email communications are not always secure; please do not include credit card information or other sensitive information in your
emails to us.