Privacy Policy
1. Introduction
Conley Chaos LLC, doing business as Adaptiv ("Adaptiv," "we," "us," or "our"), is committed to protecting your privacy and being transparent about how we collect, use, and protect your information. This Privacy Policy explains our data practices for our website at tryadaptiv.com and the custom software and operational services we provide to real estate syndicators and related private-capital firms (collectively, "Services").
This policy applies to information we collect from prospective clients, current clients, visitors to our website, and individuals whose information we process on behalf of our clients in the course of providing Services. It does not apply to information collected by third-party websites, platforms, or services that may be linked from our site.
When we process personal data on behalf of a client — for example, limited partner records, investor contact lists, or fund-related documents handled as part of a custom engagement — we act as a service provider or processor at the direction of that client. In those cases, our handling of personal data is primarily governed by the relevant Service Agreement and, where applicable, a separate Data Processing Addendum ("DPA"). Please contact your firm for the privacy policy that applies to information collected by the client directly.
By using our website or engaging our Services, you agree to the collection and use of information as described in this Privacy Policy. If you are a California resident, please see Section 9 for information about your additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).
2. Information We Collect
We collect information in the following categories:
Contact and Discovery Information: Name, work email address, firm name, capital-raised range, current stack, and a description of the operational friction points you are trying to solve, collected when you complete the discovery form on our website, contact us by email, or otherwise request information about Adaptiv. Account Information: If you create a client-portal account on tryadaptiv.com, we collect your name, email address, an authenticated credential (handled through a password hash or magic-link flow), and account metadata such as account creation date, email verification status, and role. Session and Technical Data: When you sign in, we record session identifiers, session tokens, IP addresses, user-agent strings, and the time of access, solely to operate the authentication system, protect against fraud, and maintain security logs. Business and Engagement Information: Details about your firm's operations, capital structure, existing technology stack, vendor relationships, workflows, and any other information you share with us to help us design and deliver a custom operating system for your firm. Client System Data (Processor Role): When we are engaged to build, integrate, or operate a custom system for your firm, we may access, process, and route data stored in your CRM, investor portal, accounting, property management, e-signature, and related systems on your behalf. This may include investor contact records, capital commitments, wire confirmations, fund documents, deal pipeline data, and other business-confidential information belonging to your firm and its investors. We process this data solely as directed by you and in accordance with the Service Agreement and any applicable DPA. Communications: When you communicate with us by email, form submission, phone, or other means, we retain records of those communications for service delivery, quality assurance, and record-keeping purposes. Website Usage Information: We collect standard website usage information, including pages visited, referring URLs, browser type, device type, and general geographic location derived from IP address. We use this information in aggregate to improve our website and understand how visitors use it.
We collect information directly from you, automatically through your use of our website, and from third-party platforms that you authorize us to access as part of our Services.
3. How We Use Information
We use the information we collect for the following purposes:
Responding to Inquiries: To reply to discovery requests, schedule walkthroughs, and communicate with prospective clients about whether Adaptiv is a fit for their firm. Service Delivery: To design, build, integrate, and operate the custom software described in your Service Agreement, including the deployment and ongoing operation of AI agents that perform work across your connected systems. Client Communication: To respond to your inquiries, send service-related notifications, provide project updates, and communicate about your account. System Integrations: To connect, configure, and maintain integrations between your business platforms, including CRM systems, investor portals, accounting and property management tools, and e-signature providers. Authentication and Security: To operate the client-portal login, verify your identity, maintain sessions, detect fraud or unauthorized access, and protect the integrity of our Services. Website Improvement: To analyze how visitors interact with our website and improve our content, design, and user experience in aggregate. Legal Compliance: To comply with applicable laws, regulations, legal process, or enforceable governmental requests, and to enforce our Terms of Service. Business Operations: For internal purposes such as invoicing, recordkeeping, fraud prevention, and ensuring the security and integrity of our Services.
We do not use your information for automated decision-making that produces legal or similarly significant effects without human review. We do not sell your personal information to third parties, and we do not share your personal information for cross-context behavioral advertising.
4. Payment Information
Where Adaptiv bills you directly for Services, payment information may be processed through third-party payment processors identified in your Service Agreement. Adaptiv does not directly collect, store, process, or have access to your complete credit card numbers, bank account numbers, or other sensitive payment instrument details except as expressly set forth in your Service Agreement. All such payment transactions are transmitted directly and securely to those processors, which are PCI-DSS compliant and operate under their own privacy policies and security programs.
We may receive and retain limited payment-related information from our processors, such as the last four digits of your card, card brand, billing postal code, and transaction confirmation status, solely for accounting, customer service, and fraud prevention purposes.
5. Information Sharing and Third-Party Services
We do not sell, rent, or trade your personal information. We share information only as described below:
Hosting and Infrastructure: Our website, client portal, and back-end systems are hosted on infrastructure provided by Cloudflare, Inc., including Cloudflare Workers, D1, Queues, and related services. Cloudflare processes data as our service provider under its own security and data protection program. Email Service Providers: We use Resend (resend.com) to send transactional and service-related emails, including discovery-request confirmations, magic-link sign-in emails, and password-reset emails. Your contact information is shared with Resend solely for this purpose. Authentication Providers: We use the better-auth open-source authentication library to operate account, session, and credential storage. Authentication data is stored within our Cloudflare D1 database and not shared with any third party beyond our hosting infrastructure. Client Systems: When we provide integration or operational services, we interact with third-party CRM, investor portal, accounting, property management, e-signature, and reporting systems on your behalf. The data involved is your firm's business data, and our access is governed by your Service Agreement and the terms of those platforms. AI Model Providers: To power AI agents, we may transmit portions of Client Content or session data to one or more AI model providers identified in your Service Agreement. We use reputable providers and contract for enterprise-grade data handling (including no-training and data-retention controls) where available. Specific providers and controls for each engagement are identified in your Service Agreement. Payment Processors: As described in Section 4. Professional Advisors: We may share information with our attorneys, accountants, and other professional advisors under obligations of confidentiality when necessary for our business operations. Legal Requirements: We may disclose information if required to do so by law, court order, or governmental authority, or if we reasonably believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud. Business Transfers: If Adaptiv or Conley Chaos LLC is involved in a merger, acquisition, asset sale, or reorganization, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a materially different privacy policy.
6. Cookies and Tracking
Our website uses a minimal set of cookies and similar tracking technologies, limited to what is necessary to operate the site and the client portal. Specifically, we use session cookies to keep you signed in, and limited usage cookies to understand aggregate website usage patterns. We do not use third-party advertising cookies, advertising pixels, or build behavioral profiles for advertising purposes.
You can control cookies through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. Disabling cookies may affect the functionality of the client portal. We do not currently respond to browser "Do Not Track" signals, as no uniform standard for honoring such signals has been adopted.
We do not engage in cross-site behavioral tracking for advertising.
7. Data Security
We take data security seriously and implement industry-standard technical and organizational measures to protect the information we collect and process. These measures include encrypted data transmission (TLS/HTTPS), encryption at rest via our hosting infrastructure, hashed password storage, access controls that limit who can access client data, regular software updates, and use of reputable, security-certified infrastructure providers.
However, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of your information. In the event of a data breach affecting your personal information, we will notify affected individuals and regulators as required by applicable law.
You are responsible for maintaining the confidentiality of any login credentials or access tokens you share with us. Please notify us immediately at hello@tryadaptiv.com if you suspect any unauthorized access to your account or data.
8. Data Retention
We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, to perform our Services under an active agreement, and to comply with our legal obligations. After our engagement ends, we generally retain business records for a period of seven (7) years as required for tax and accounting purposes, unless a longer or shorter retention period is required by law.
When we access client CRM, investor portal, accounting, or other business system data as part of our Services, we do not retain copies of that data beyond what is necessary to perform the Services. Copies of that data are deleted or returned to you upon termination of the relevant Service, subject to applicable legal hold obligations.
Analytics data collected through our website is retained in aggregate form indefinitely. Individually identifiable usage data is retained for no more than twenty-four (24) months. Discovery-form submissions are retained until we determine the inquiry is closed or the prospect has requested deletion.
9. California Privacy Rights (CCPA / CPRA)
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):
Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it. Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions (such as information necessary to complete a transaction, detect security incidents, comply with legal obligations, or exercise free speech). Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you. Right to Opt-Out of Sale or Sharing: We do not sell your personal information to third parties, and we do not share your personal information with third parties for cross-context behavioral advertising. You therefore do not need to opt out of a sale or sharing that does not occur. Right to Limit Use of Sensitive Personal Information: To the extent we collect sensitive personal information (as defined by CPRA), you may have the right to limit our use of such information. Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you services, charge you different prices, or provide a different level of quality of service because you exercised a privacy right.
To exercise any of these rights, please submit a verifiable consumer request to hello@tryadaptiv.com. We will respond within the time periods required by applicable law (generally 45 days, with the ability to extend by an additional 45 days with notice). We may need to verify your identity before processing your request.
10. Children's Privacy
Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. Our website and marketing materials are intended solely for adults operating or employed by real estate firms and their service providers.
If we learn that we have inadvertently collected personal information from a child under 13 without verified parental consent, we will delete that information as quickly as practicable. If you believe we have collected information from a child under 13, please contact us immediately at hello@tryadaptiv.com so we can address the situation.
11. International Data Transfers
Adaptiv operates primarily from the United States, and our infrastructure providers (including Cloudflare) may process data across a global network of servers for performance, reliability, and security purposes. If you access our website or Services from outside the United States, your information may be transferred to, stored, and processed in the United States and in other countries where our service providers operate. By using our Services, you consent to such transfers, subject to the protections described in this Privacy Policy and any applicable legal safeguards.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will post any changes to this page with an updated effective date. Where changes are material, we will make reasonable efforts to notify active clients by email at least 30 days before the changes take effect.
Your continued use of our website or Services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Email: hello@tryadaptiv.com Website: tryadaptiv.com Legal Entity: Conley Chaos LLC, doing business as Adaptiv State of Formation: California
We will respond to all privacy-related inquiries within a reasonable time and within any timeframes required by applicable law.